Effect of Supreme Court decision
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
Our ref: FOI2018/02175
Dear Mr Webber,
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Thank you for your communication of 2nd October which has been passed to
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HMRC Freedom of Information Act Team
Dear Mr Webber
I am writing in response to your request for information, received 2
October 2018.
Yours sincerely,
HMRC Freedom of Information Team
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