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HMRC v Murray Group and others

In HMRC v Murray Group and others (FTC/15/2013 – 8 July 2014) the UT dismissed HMRC’s appeal remitting part of it to the FTT for further determination.

MGM (a company of the Murray Group) had set up an employee remuneration trust which had in turn set up sub-trusts for some 108 employees (all footballers). The sub-trusts were financed by loans of the company to the head trust. The loans had not been repaid.

The question was whether there had been a payment of earnings by MGM to the employees (ITEPA 2003 s 62).

The UT first noted that the FTT’s approach seemed to have been influenced by Mayes [2009] EWHC 2443 in considering that the steps under consideration ‘were genuine legal events with real legal effects’ thus constraining the application of the Ramsay doctrine to the case. The UT observed that the relevant provisions in this...

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