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08 July 2014

UT Decision: HMRC v Murray Group Holdings

Income Tax and NIC – emoluments/earnings – tax avoidance scheme – remuneration trust – employees’ individual sub-trusts – “protectors” – (1) whether payments into sub-trusts were emoluments/earnings subject to PAYE and NIC; – No (2) whether loans from sub-trusts were emoluments/earnings subject to PAYE and NIC; – No (3) “Ramsay” principle – whether FTT erred in law; – No – Case remitted to FTT to determine certain matters, but otherwise appeal dismissed.

Andrew Thornhill QC, Jonathan Bremner & Thomas Chacko, instructed by HJB Gateley, acted for the Murray Group.

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