Rangers v Advocate General for Scotland [2017] WTLR 1093

Wills & Trusts Law Reports | Autumn 2017 #169

The appeal concerned a tax avoidance scheme by which employers paid remuneration to their employees through an employees’ remuneration trust in the hope that the scheme would avoid liability to income tax and Class 1 national insurance contributions. The question on appeal was whether an employee’s remuneration was taxable as their emoluments or earnings when it was paid to a third party in circumstances in which the employee had no prior entitlement to receive it himself or herself.

The employing companies, including RFC, operated the tax avoidance scheme in the tax years between...

Trustees: A red card?

Catharine Bell and Nicole Aubin-Parvu review a case that highlights the importance for trustees of impartiality and independence when handling EBTs ‘There was, in fact, evidence to suggest that the trust was intended to be operated in breach of trust and that the scheme required such breach to achieve its purpose.’ The decision of the …
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