Advocate General for Scotland v Murray Group Holdings Ltd and others

Income tax – Emoluments – Tax avoidance scheme. Court of Session: Allowing an appeal by the Advocate General, representing HM Revenue and Customs, the court held that a scheme the respondent companies had entered into, involving payments to various trusts and application of the monies so paid, which was designed to avoid payment of income tax and National Insurance contributions in respect of their employees, amounted to a mere redirection of earnings which did not remove the liability of employees to income tax.

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