Case: HMRC succeeds in Rangers EBT case

In RFC 2012 Plc (in liquidation) v Advocate General for Scotland [2017] BTC 22, the Supreme Court dismissed the taxpayer’s appeal; money paid under a tax avoidance scheme into an EBT constituted earnings to which PAYE deductions should have been applied, since such money was a component of each footballer’s remuneration

Lord Hodge, giving the judgment of the Court, said the central concept in the tax regime governing employment income was the payment of emoluments or earnings derived from employment; and an employer who pays emoluments or earnings to or on account of an employee is obliged to deduct tax in accordance with the PAYE Regulations.

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