In an important Court of Appeal decision (Hoey and others v HMRC [2022] EWCA Civ 656), the Court rejected the taxpayer’s appeal in a disguised remuneration loan scheme, whereby he sought to obtain a credit for notional PAYE on employment income paid through a third party.
The case involved an IT contractor, Mr Hoey, who worked in the UK for a variety of UK based entities (the en...
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