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Looking both ways

13 December 2011 / Andrew Hubbard
Issue: 4334 / Categories: Comment & Analysis , Employees , Income Tax
ANDREW HUBBARD, aficionado of conundrums, casts a wry eye over the Court of Appeal’s decision in the PA Holdings case

KEY POINTS

  • Employee bonus tax avoidance scheme.
  • Impact of TA 1988 s 20(2).
  • Nature of income received by employees.
  • Salary versus dividend payments.

‘The question is ’ said Humpty Dumpty ‘which is to be master – that’s all.’

Q: When is a door not a door?

A: When it’s ajar.

I have always had an interest in logic puzzles and paradoxes. Get me in the right mood at a party and I will talk for hours about white ravens and how the tortoise and the hare proved that all motion is impossible. (You have been warned!)

Perhaps not surprisingly therefore one of my favourite authors is Lewis Carroll.

In the past I have often found myself thinking that Alice's Adventures in Wonderland is as good a guide to the complexities...

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