The First Tier Tribunal (FTT) has dismissed the appeal from CIA Insurance Services Ltd ruing that HMRC had correctly denied corporation tax relief for contributions worth £9.6m made to a remuneration trust, stating that the loans made out of the contributions were disguised remuneration and were liable for both PAYE and National Insurance contributions (NICs).

CIA Insurance Services Ltd (CIA) was an insurance company and in 2010 entered a tax avoidance scheme called the Remuneration Trust arrangement marketed by Baxendale Walker Solicitors.