07-11-2015, 03:22
(This post was last modified: 07-11-2015, 03:38 by Larry-AV.
Edit Reason: Typo.
)
Having ploughed through the Court of Session Judgement, its key points are :
1} The payments from Rangers (and other respondents) to the Principal Trust constituted redirection of emoluments, i.e., payment for services rendered by the employee to their employer through their work.
2} Being emoluments, they are subject to Income Tax, prior to their transfer to the Principal Trust. That means the employers (including Rangers) should have paid income tax prior to the transfer of funds.
3} Any transfer of monies between the Principal Trust and the Sub-Trusts would be subject to taxation too, but that would be under the taxation applicable to Trusts and not the taxation applicable to income.
This is the latest judgement in this saga; whether BDO appeals against it remains to be seen.
1} The payments from Rangers (and other respondents) to the Principal Trust constituted redirection of emoluments, i.e., payment for services rendered by the employee to their employer through their work.
2} Being emoluments, they are subject to Income Tax, prior to their transfer to the Principal Trust. That means the employers (including Rangers) should have paid income tax prior to the transfer of funds.
3} Any transfer of monies between the Principal Trust and the Sub-Trusts would be subject to taxation too, but that would be under the taxation applicable to Trusts and not the taxation applicable to income.
This is the latest judgement in this saga; whether BDO appeals against it remains to be seen.
AVFC RFC SAFC