The Commissioners for HM Revenue and Customs v Murray Group Holdings Limited and Others: [2014] UKUT 0292(TCC)

Upper Tribunal Tax and Chancery decision of Lord Doherty on 8 July 2014.

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Income Tax and NIC 鈥 emoluments/earnings 鈥 tax avoidance scheme - remuneration trust 鈥 employees鈥 individual sub-trusts 鈥 鈥減rotectors鈥 - (1) whether payments into sub-trusts were emoluments/earnings subject to PAYE and NIC; -No (2) whether loans from sub-trusts were emoluments/earnings subject to PAYE and NIC; -No (3) 鈥淩amsay鈥 principle - whether FTT erred in law; - No - Case remitted to FTT to determine certain matters, but otherwise appeal dismissed.

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Published 1 December 2016