13 July 2017
RFC 2012 Plc (in liquidation) (formerly Rangers Football Club Plc) v Advocate General for Scotland [2017] UKSC 45, [2017] All ER (D) 19 (Jul)
In proceedings concerning a tax avoidance scheme by which employers paid remuneration to their employees through an employees’ remuneration trust (consisting of a principal trust and sub-trusts), it was not necessary that the employee himself should receive, or at least be entitled to receive, the remuneration for his work in order for that reward to amount to taxable emoluments. Accordingly, the Supreme Court, in dismissing the appellant’s appeal, held that payments made to the principal trust should have been subject to deduction of income tax.
