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Avonside Roofing Ltd v HMRC

Avonside Roofing Ltd v HMRC [2021] UKFTT 158 (TC) (15 May 2021) examines the validity of an information notice issued under FA 2008 Sch 36 by HMRC to the appellant company.

The company had implemented tax avoidance arrangements in 2009/10. The type of arrangement involved the making of an employer contribution to establish an employee benefit trust and not accounting for PAYE on those contributions. Avonside relied on its reputable adviser and on the promoter of the arrangements and believed that the scheme would be effective; it was not until the conclusion of the Rangers litigation (RFC 2012 Plc [2017] UKSC 45) that it became clear this was not the case.

HMRC became aware that Avonside had participated in this type of arrangements. Their position was that the amounts paid to the settlor of the EBT should have been included in the company's PAYE return. They issued a determination under...

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