HMRC said the taxpayer promoted ‘corporate remuneration trust scheme’ arrangements which allowed directors to extract profits from a company without incurring an income tax charge by means of a reduced salary and loans from February 2011 to April 2016. It applied for an order under FA 2004 s 314A that the scheme was notifiable under the disclosure of tax avoidance scheme (DOTAS) rules (FA 2004 s 306(1)). The order specified the taxpayer as the ‘promoter’ (FA 2004 s 307).
The First-tier Tribunal considered the arrangements fell within s 306(1) because they enabled participants to obtain a tax advantage and this was a main benefit expected to arise from them. Further the arrangements met the prescribed descriptions of confidentiality payment of a premium fee and standardised tax products. The tribunal concluded they were notifiable for the purposes of s 306.
The taxpayer said it was not...
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