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United Kingdom
Aberdeen Asset Management plc v HMRC
[2013] CSIH 84, [2014] STC 438 (Inner House, Court of Session — NOT a UK Supreme Court decision; original metadata court and 2017 year are incorrect)
Key Principle
Where an employer used an employee-benefit-trust 'discounted options' scheme to deliver bonuses through shares in offshore companies pre-funded with the bonus amounts, the shares (or the underlying cash) constituted earnings paid as readily convertible assets, so the employer was liable to account for PAYE income tax and Class 1 National Insurance contributions on them.
Area of Law
tax
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