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Spotlight 52 Disclosure of Tax Avoidance Schemes: tax avoidance using offshore trusts

HMRC have issued Spotlight 52 about two First-tier Tribunal cases using schemes to disguise income on which income tax and National Insurance contributions were due.

HMRC have successfully argued two cases in the First-tier Tribunal (FTT), involving Hyrax Resourcing Ltd and Curzon Capital Ltd. The FTT decided in both cases that the disguised remuneration arrangements being promoted were notifiable under the Disclosure of Tax Avoidance Schemes (DOTAS) legislation. In both cases, the arrangements were designed to disguise income for which tax and National Insurance contributions would be due. Scheme users were rewarded with amounts paid as loans which they ultimately owed to an offshore benefit trust.

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