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Tower Radio and Total Property Support Services v HMRC

In Tower Radio and Total Property Support Services v HMRC [2015] UKUT 60 (13 February 2015) the UT found that a scheme devised to avoid income tax and NIC deductions on payments to employees was effective.

Tower and Total had implemented a scheme to pay bonuses to employees without attracting income tax and NIC deductions. This was to be achieved by awarding the employees shares in specially formed subsidiaries and thus taking advantage of ITEPA 2007 Part 7 which contains special rules for the acquisition of shares in connection with employment. The issue was whether in the light of the Ramsay principle and ‘taking a realistic view of the facts’ the employees should be regarded as having acquired money rather than shares .

The UT found that the employees had been awarded shares not money for the following reasons (inter alia):


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