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High Court affirms the Tax Appeals Commissioner's determination that the taxpayers, directors of a company, are not 'proprietary directors' and are therefore entitled to transborder workers relief (TWR) for their UK-based employment income, on the grounds that there was no error in the Tax Appeals Commissioner's interpretation of the relevant sections of the applicable statute, and that the taxpayers did not control more than 15% of the ordinary share capital of the company and were correctly granted TWR.
Transborder Workers Relief (TWR) - proprietary director - Taxes Consolidation Act 1997 - ordinary share capital -Tax Appeals Commissioner (TAC) - Revenue Commissioners - High Court - statutory interpretation - beneficial ownership - control test - non-voting shares - tax residency - PAYE - National Insurance Contributions (NIC) - shareholders' rights - company law.
Note: This is intended to be a fair and accurate report of a decision made public by a court of law. Any errors should be notified to the editor and will be dealt with accordingly.
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