The Resource Aberdeen Asset Management plc v HMRC : flow and ebb of legislative volume

Aberdeen Asset Management plc v HMRC : flow and ebb of legislative volume

Label
Aberdeen Asset Management plc v HMRC : flow and ebb of legislative volume
Title
Aberdeen Asset Management plc v HMRC : flow and ebb of legislative volume
Creator
Subject
Language
eng
Summary
This case note discusses the case of Aberdeen Asset Management plc (Aberdeen) v HMRC. Aberdeen is a member of a group of investment companies. It entered arrangements to seek to pay its top employees in a way that meant there was next to no income tax due, and in any event no liability to PAYE or national insurance contributions when money left Aberdeen. For this purpose Aberdeen established an employee benefit trust (EBT). This was a discretionary trust, the trustees were resident in the Isle of Man and the beneficiaries were employees of Aberdeen. Aberdeen put money in the trust. The mechanics of this case involved a large number of employees, who received bonuses via an offshore employment benefits trust (EBT) which created separate "money-box" companies for the employees entitled to a bonus.The issue was whether this structure avoided income tax. This case note discusses the case and looks if the Ramsay principle is still sufficient
Citation source
In: British tax review. - London. - (2014),
http://library.link/vocab/creatorName
Simpson, P
Geographic coverage
  • Europe
  • European Union
Language note
English
http://library.link/vocab/subjectName
  • case law
  • trust
  • Ramsay principle
  • employment income
  • tax avoidance
Label
Aberdeen Asset Management plc v HMRC : flow and ebb of legislative volume
Instantiates
Publication
Label
Aberdeen Asset Management plc v HMRC : flow and ebb of legislative volume
Publication

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