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You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> DELPHI DERIVATIVES LIMITED v Revenue & Customs (PENALTY - Schedule 24 Finance Act 2007 - Employee Benefit Trust ('EBT') Clavis Scheme whereby EBT contributions made via a service provider) [2023] UKFTT 722 (TC) (18 August 2023) URL: https://www.bailii.org/uk/cases/UKFTT/TC/2023/TC08912.html Cite as: [2023] UKFTT 722 (TC), [2024] SFTD 448 |
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Decision Number: | TC 08912 |
Appellant: | ![]() ![]() ![]() ![]() |
Respondent: | His Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Dr Heidi POON |
Date Of Decision: | 18/08/2023 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | PENALTY - Schedule 24 Finance Act 2007 - Employee Benefit Trust (-˜EBT-™) Clavis Scheme whereby EBT contributions made via a service provider - allocations to sub-trusts for loans to be advanced to directors - Scheme ineffective to avoid income tax and national insurance on contributions into sub-trusts following Rangers - inaccuracies in returns for omission of PAYE and NICs on loans made via the sub-trusts ¬-“ whether inaccuracies -˜careless-™ due to failure to take reasonable care ¬-“ the nexus for a -˜careless-™ inaccuracy for Sch 24 purposes distinguished from -˜causation-™ have ![]() |