In Murray Group Holdings Ltd v HMRC (and related appeals) (TC02372 – 20 November) a company (MG) provided management services to a group of companies which included a major football club. In 2001 the group established an employees’ remuneration trust for the benefit of employees and their families. Group companies paid money into the trust with a direction to the trustees to establish and fund a sub-trust for the benefit of the family of a particular employee and make a loan facility available to the employee. HMRC issued determinations under SI 2003/2682 reg 80 on the basis that the various payments were emoluments of the employees’ employment and were liable to PAYE and NIC. MG and four associated companies appealed. The First-tier Tribunal allowed the appeals in principle (by a 2:1 majority). Judge Mure held that ...
