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The final score.
KEY POINTS
- The Supreme Court finds in favour of HMRC on payments to employment benefit trusts.
- The definition of ‘employee’ within the subordinate legislation also proved persuasive.
- It was not necessary for an employee to receive remuneration for it to constitute emoluments.
- Could this concept result in a tax charge if the employee is not entitled to receive the money?
- How will this judgment influence other cases with equivalent arrangements?
The long-running dispute about the tax treatment of the Murray Group’s funding of a remuneration trust for its employees has been resolved at the Supreme Court and on 5 July Lord Hodge delivered its judgment in favour of HMRC. The case was RFC...
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