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”
Sham
‘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!
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SIDE LETTERS, bring out your side letters……….
It may continue to be funny.
They didn’t need to die…….chuckle, chuckle…….
Barca 1 up
miki67
16:56 on 20 November, 2012
Oho!
Methinks this is all the way of the future : emoluments as loans (never to be repaid), this will be the stock answer for the taxman et al should they ever come calling. Nice precedent set by the fine and upstanding (though apparently prematurely deceased; how funny is that?) rankers. The gates of hell just opened for HM Treasury.
: > )
FTT can’t be used as precedent. Only cases in court of law