[2009] UKFTT 95 (TC)

[The appeal against this decision is reported at [2010] BTC 1,626.]

Upper Tribunal Judge David Williams (Chairman), Tribunal Judge Adrian Shipwright (formerly special commissioners of income tax)

Decision released 7 May 2009

Income tax – other – whether sums paid to individuals by a company as a dividend financed from a capital contribution to the company from employee benefits funds derived from the individualsʼ employing company a distribution chargeable under Schedule F or emoluments from employment under Schedule E and subject to the PAYE Regulations – rules requiring exclusivity of Schedules applied

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