THE COMMISSIONERS FOR HIS MAJESTY’ S REVENUE AND CUSTOMS v MARLBOROUGH DP LIMITED [2024] UKUT 00098 (TCC) (Final Principal decision)
Upper Tribunal Tax and Chancery decision of Mr Justice Edwin Johnson and Judge Guy Brannan on 12 April 2024
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INCOME TAX – tax avoidance scheme – whether amounts paid by respondent under trust arrangements taxable as earnings from employment under s62 ITEPA 2003 – whether taxable as earnings under Part 7A ITEPA 2003 because paid “in connection with” employment – Edwards v Bairstow challenge – appeal allowed in part – observations in relation to applications for permission to appeal and pleadings before the Upper Tribunal where an Edwards v Bairstow challenge is made
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Published 16 April 2024