Effect of Supreme Court decision

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Dear HM Revenue and Customs,

In July 2017 the Supreme Court handed down their decision in the Rangers Football Club case. This decision confirmed HMRC's view that payments made to employees but the employer, but via a third party (in that case a trust), should have been subject to PAYE deductions at source. As a result the Reg 80 PAYE Regulations 2003, determinations were confirmed and HMRC was able to collect the sums due.

Can HMRC please advise me:

1. How many Regulation 80 determinations have been issued based on this decision?
2. How many of those have been appealed?
3. Has HMRC issued Follower Notices as a result of the decision and how many?
4. Has HMRC used the decision to issue GAAR Pooling notices and how many?

Many thanks

Yours faithfully,

Graham Webber

Tax Director, WTT Consulting

foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team, HM Revenue and Customs

Our ref: FOI2018/02175

Dear Mr Webber,

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HMRC Freedom of Information Act Team

foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team, HM Revenue and Customs

1 Attachment

Dear Mr Webber

I am writing in response to your request for information, received 2
October 2018.

Yours sincerely,

HMRC Freedom of Information Team