Tax analysis: In CIA insurance Services Ltd v HMRC, the First-tier Tax Tribunal (FTT) held that contributions by the company to a remuneration trust were not allowable deductions for corporation tax purposes and that the loans made by the trust to employees were chargeable to income tax (and NICs) under the disguised remuneration rules in Part 7A of the Income Tax (Earnings and Pensions) Act 2003.
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