Gold bullion scheme fails at the tribunal

The First-tier Tribunal heard Wired Orthodontics (TC8679) in July 2022 with the judgment dated 6 January 2023. The case names the employer Wired Orthodontics Ltd and also the two directors Ian Hutchinson and Susan Bessant who were associated parties to the appeal.

The case relates to an arrangement set up by a particular promoter for the benefit of the company to avoid PAYE tax and National Insurance arising on a proposed payment of £300 000 which was to be made to the two named directors.

The structure of the scheme was for the company to set up an employee benefit trust (EBT) for the benefit of the two directors. This happened in October 2014. It was specified within the arrangement that it was the intention that £300 000 would be contributed into the EBT within a ten-year period. The two named directors received £300 000 worth of...