Employee Benefit Trusts – HMRC win against Rangers FC

The Court of Sessions in Scotland have overturned previous Tribunal decisions and found in favour of HM Revenue & Customs. The judges have decided that payments by Rangers FC to the principal trust of an employee benefit trust amount to “a mere redirection of emoluments and earnings” and therefore were subject to income tax and…

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Opening the envelope? STEP Journal publishes our “Pros and cons of de-enveloping UK residential property”

Mark Davies, Jon Elphick and Nick Beresford consider the benefits of unwinding an existing offshore structure. KEY POINTS What is the issue? Further changes are being introduced that will result in offshore structures owning UK residential property becoming less attractive from a tax perspective. What does it mean for me? These structures need to be reviewed to…

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Proposed reforms to the taxation of non-doms announced by Treasury

Summary of Consultation Paper issued 30 September 2015  Government’s stated policy aims:- Persons who are UK resident in 15 out of the last 20 tax years will become “deemed domiciled”. They will pay tax on their worldwide personal income and gains, but foreign income and gains sheltered within an offshore trust will escape taxation. Persons…

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