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Non-Employee Remuneration Trusts given green light by Robert Venables QC
06-24-2011, 10:03 PM
Post: #1
Non-Employee Remuneration Trusts given green light by Robert Venables QC
Summary of Advice

7. In my Opinion, the Remuneration Trust Deed settled by me for my Instructing Solicitor has the effect that:

(1) contributions to it are not prevented from being immediately deductible for corporation tax purposes by the Unpaid Remuneration Rules (i.e. Corporation Tax Act 2009 sections 1288 and 1289);

(2) contributions to it are not prevented from being immediately deductible for corporation tax purposes by the Employee Benefit Contributions Rules (i.e. Corporation Tax Act 2009 sections 1290 to 1296);

(3) the settled property should fall within Inheritance Tax Act 1984 section 86;

(4) the proposed new Part 7A of Income Tax (Earnings and Pensions) Act 2003 should not apply to the trusts and powers created by it.

8. Although my Opinion 1103 focussed on the position where the Founder of the Remuneration trust is a body corporate within the charge to corporation tax, the draft Remuneration Trust Deed can be adapted for the case where the Founder is not such a body corporate and the like consequences should in my view follow.

Full Document attached:

.pdf  1104 Summary of Opinion 1103 re Draft Remuneration Trust Deed.pdf (Size: 80.79 KB / Downloads: 68)
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Non-Employee Remuneration Trusts given green light by Robert Venables QC - BAXENDALE WALKER LLP - 06-24-2011 10:03 PM

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