Stephen Oliver QC

Decision released 26 April 2006

National Insurance contributions – Secondary Class 1 Contributions payable by employer – whether transfers of gold Napoleon coins invariably followed by the immediate sale of the coins for cash were to be disregarded as earnings, as constituting ‘payments in kind’ – how Ramsay principles were to be applied following the decisions in MacNiven v. Westmoreland Investments Ltd and Barclays Finance Limited v. Mawson – whether similar transfers after April 1995 were transfers of assets for which ‘trading arrangements’ existed – Appeal dismissed

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