Successful times for HMRC
HMRC have had a good run in the courts recently winning two important victories.
The Supreme Court ruled that the share awards made to UBS/Deutsche Bank staff should be subject to income tax on their value on acquisition.
Meanwhile the First Tier Tribunal ruled in HMRC’s favour in its dispute with Stagecoach. In outline the company had undertaken some planning to create a tax deduction on a loan but the Tribunal found that no relief could be claimed.
As both of these appear to involve structured planning it is likely that HMRC will now be looking at other uses of the arrangements.
Date: 7th April, 2016
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