Was payment to employee benefit trust earnings?..MR Currell Ltd v HMRC. MR Currell Ltd (M) made a payment of £800,000 to a director via an employee benefit trust (EBT), purportedly as a loan. HMRC
insisted this should be taxed as “earnings”. The First-tier Tribunal (FTT) agreed with HMRC, saying “it was more likely than not that the loan was...
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