Scheme to avoid tax and NICs on bonuses using restricted securities fails (FTT)

The First-tier Tribunal has ruled that a scheme to pay tax-free bonuses in the form of restricted securities failed. The scheme's main purpose was tax avoidance, and on a purposive interpretation the exemptions in the restricted securities legislation did not apply. The tribunal referred to points of principle decided in UBS AG v HMRC [2010] UKFTT 366 (TC), which was heard consecutively (but separately) by the same tribunal. (Deutsche Bank Group Services (UK) Limited v The Commissioners for HMRC [2011] UKFTT 66 (TC).)

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