Chancery Division.

Hart J.

Judgment delivered 28 October 1999.

Income tax – PAYE – Scheme to avoid NIC – Bonuses awarded to directors in the form of contingent reversionary interests in overseas trusts – Whether there was a ‘payment’ to directors – Whether Ramsay principle applied – Whether payment by intermediary – Whether the interest was a ‘tradeable asset’ as a result of ‘trading arrangements’ – Income and Corporation Taxes Act 1988, s. 203, 203B, 203F, 203K.

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