CIA insurance Services Ltd v HMRC

In CIA insurance Services Ltd v HMRC [2022] UKFTT 144 (TC) (4 May 2022) the FTT held that contributions by the company to a remuneration trust were not allowable deductions for corporation tax purposes and that the loans made by the trust to employees were chargeable to income tax (and NICs) under the disguised remuneration rules in ITEPA 2003 Pt 7A.

CIA an insurance broker was a subsidiary of another company which was in turn wholly owned by three individuals each of which was an employee of CIA and two of whom were directors. The company made contributions to a trust and those contributions were used to make loans to the three individuals. Over the three years which were the subject of the appeal the total loans exceeded £9.5m. Each loan was made under a finance agreement for a period of ten years plus one day....

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