An anonymised version of the First Tier Tribunal verdict was published by the Finance and Trbunals service today. The 145 page document will take some reading but it concluded:
“the trust payments are to be construed as ‘emoluments’ for the purposes of the tax legislation”
For those without a dictionary to hand,… Emoluments: Synonyms earnings, pay, recompense.
I for one am absolutely shocked that Sir David’s confidence was misplaced on this matter.
Enjoy the game!
“having ascertained the real nature of the transaction, you cannot … disguise it by using camouflaged clothing”
‘it is wrong and an unnecessary self-limitation’ not to give regard to ‘the manifested intentions of the parties’ in the face of documents or transactions that are not ‘shams’
Orders are now open for the very first CQN Annual, get it here![calameo code=0003901717b03ef5e64cb lang=en page=100 hidelinks=1 width=100% height=500]