Sempra Metals Ltd v HM Revenue and Customs
| Jurisdiction | England & Wales |
| Date | 2008 |
| Court | Special Commissioners |
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17 cases
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RFC 2012 Plc ((in Liquidation)) (formerly The Rangers Football Club Plc) v Advocate General for Scotland
...placed unreservedly at the disposal of the employee. Yet it has been so used. 55 In Sempra Metals Ltd v Revenue and Customs Comrs [2008] STC (SCD) 1062 one of the issues which the Special Commissioners had to address was whether payments by the taxpayer company of senior employees' bonuses......
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Advocate General for Scotland v Murray Group Holdings Ltd
...[75] Reference was also made to the decision of the Special Commissioners in Sempra Metals Ltd v Revenue and Customs Commissioners, [2008] STC (SCD) 1062. That case was concerned with an employee benefit trust into which bonuses were paid; the employee had a choice between taking a bonus in......
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Michaela Joy Hall (as Liquidator of Ethos Solutions Ltd) v Muhammad Nasim & 62 Others
...time that it was incorporated, the tax treatment of such arrangements was governed by Sempra Metals Ltd v Revenue and Customs Comrs [2008] STC (SCD) 1062. 10 On 9 December 2010, the Government announced that it was introducing legislation to change the tax treatment of such arrangements. In......
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Christopher Purkiss (as Liquidator of Ethos Solutions Ltd) v Tim Kennedy & 34 Others
...courts did not accept HMRC's views on the tax consequences of loan schemes. In Sempra Metals Ltd v Revenue and Customs Commissioners [2008] STC (SCD) 1062, the court had rejected the argument that loans made by an employer's EBT were subject to income 6 HMRC made some progress in 2010. On 2......
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1 firm's commentaries
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Income Tax Planning And Osborne's First Budget
...income tax and NICs. We know this because this was the substance of their argument in Sempra Metals Ltd –v- Commissioners of HMRC [2008] STC (SCD) 1062 HMRC succeeded in preventing a Corporation Tax deduction for payments to an FBT but failed in their argument that loans to Beneficiaries we......
1 books & journal articles
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Comment on the decision in RFC 2012 Plc (in liquidation) v Advocate General for Scotland [2017] UKSC 45
...the First-tier Tribunal and the Upper Tribunal. 7Dextra Accessories (n 5) [17]. 8Sempra Metals Ltd v Revenue and Customs Comrs [2008] STC (SCD) 1062. 9MacDonald (Her Majesty's Inspector of Taxes) v Dextra Accessories Ltd. & Others [2005] UKHL 47. 10Barclays Mercantile Business Finance Ltd v......