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HUI LING MCCARTHY reviews the Special Commissioners' decision in Sempra Metals Ltd
KEY POINTS
- In Dextra it was ruled that contributions to an EBT could be potential emoluments.
- Can a trustee be an intermediary even when the settlor no longer exists?
- Status of payments to a family benefit trust.
- The interplay between beneficial and benefit.
After the House of Lords' judgment in Macdonald v Dextra Accessories Ltd [2005] STC 1111 some might have thought that the fat lady had sung on whether corporation tax deductions were allowed to employers who contributed to pre FA 2003 employee benefit trusts (EBT) prior to the paying out of emoluments by the trustees.
It appears however that others viewed the resounding dismissal of the taxpayers' appeal in Dextra as but a subdued piping as EBT litigation is back with a vengeance in the recent Special Commissioners' case of...
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