Trusts: Shedding light on remuneration trusts

Mary Ashley reports on a rare taxpayer win Cases like Marlborough are helpful to reveal how HMRC will form its arguments when it wants a tribunal to look at the overall effect of an arrangement rather than the detail. Marlborough DP Ltd v The Commissioners for Her Majesty’s Revenue & Customs [2021] is a First-tier …
This post is only available to members.

Cases Referenced

  • HMRC v PA Holdings Ltd [2011] EWCA Civ 1414
  • Marlborough DP Ltd v The Commissioners for Her Majesty’s Revenue & Customs [2021] UKFTT 304 (TC); [2021] WTLR 1329 FTT
  • RFC 2012 plc (in liquidation) (formerly Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45
  • Scotts Atlantic Management Ltd & anor v Commissioners for HMRC [2015] UKUT 66 (TCC)