Ronnie Macdonald Avoidance Investigation Anti Avoidance Group HMRC explains what action HMRC is taking to seek to tax employee benefit trusts appropriately
Since the late 1990's HMRC has been investigating cases with employee benefit trusts (EBTs) where the employer has sought an immediate deduction for corporation tax in respect of its contributions to the EBT whilst the EBT is used to channel funds to employees without accounting for PAYE tax or NI contributions.
HMRC's first challenge before the Courts arose in the case of Dextra Accessories Ltd v Macdonald. At dispute was the deductibility of payments to the EBT for the purposes of Sch. D and the taxability and liability to NI contributions of the amounts made available to employees. HMRC argued before the Special Commissioners that...
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Ronnie Macdonald Avoidance Investigation Anti Avoidance Group HMRC explains what action HMRC is taking to seek to tax employee benefit trusts appropriately
Since the late 1990's HMRC has been investigating cases with employee benefit trusts (EBTs) where the employer has sought an immediate deduction for corporation tax in respect of its contributions to the EBT whilst the EBT is used to channel funds to employees without accounting for PAYE tax or NI contributions.
HMRC's first challenge before the Courts arose in the case of Dextra Accessories Ltd v Macdonald. At dispute was the deductibility of payments to the EBT for the purposes of Sch. D and the taxability and liability to NI contributions of the amounts made available to employees. HMRC argued before the Special Commissioners that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
