Disguised remuneration – the Strategic Branding decision

All happy families are alike; each unhappy family is unhappy in its own way. So begins Anna Karenina Tolstoy’s epic novel of family and tragedy in imperial Russia.

The idea that happy families share a fairly consistent set of attributes while the attributes which lead to an unhappy family are practically limitless has gained wide traction. It was developed by the mathematician Vladimir Arnold in his principle of fragility – a good system must meet a number of requirements simultaneously which means that good systems are inherently fragile. Sadly there is no such restriction on bad systems and so these are more likely. Which brings us to tax planning in general and disguised remuneration (DR) schemes in particular.

The year of reckoning

The year 2021 was interesting for DR schemes. Some forecast the Supreme Court’s decision in what is usually known as the Rangers...