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ROBERT FIELD and DAVID FLETCHER look at the interplay between disguised remuneration and winding up the contributing company
KEY POINTS
- Liability for tax on payments from an EBT.
- McCarthy v McCarthy & Stone plc is of limited help.
- ITEPA 2003 Part 7A and the six-year period.
- Attraction of a members’ voluntary liquidation.
The request seemed simple enough. We were asked by the director of an English company (we will call it UK Ltd) whether it could be wound up and if so whether it would be best to proceed by way of formal solvent liquidation or simply allow it to be struck off.
Our conclusion was that it could not be wound up at all but for a reason we were not expecting.
UK Ltd had been the UK arm of a hedge fund management business and is controlled by a US entity.
The US entity had received distributions...
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