HMRC vs UBS/Deutsche Bank

HMRC is going to the Supreme Court to appeal decisions made against it wrt two tax schemes operated by UBS and Deutsche Bank in 2003 and 2004, which were designed to avoid tax on bonus payments.

In the UBS and Deutsche cases, HMRC had claimed that the sums allocated to employees as bonuses at the start of each scheme were liable to income tax.

An earlier upper tribunal ruling had described both banks as adopting a (as per the FT) “carefully planned tax avoidance scheme which was designed to enable the [banks] to provide substantial bonuses to employees in the tax year 2003/04 in a way that would escape liability to both income tax and national insurance contributions”.

It is interesting that HMRC are going after schemes:

- that are over a decade old,
- no longer operate,
- were ruled legal by the court of appeal, and
- are based on restricted securities in that participants had to agree to waive their bonuses in return for shares which were locked up for a period of years. When the shares vested they were taxed on the value in the form of CGT.

The case will go before the Supreme Court later this year.

Tax does have to be taxing.

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