Buckingham Wealth Ltd
- Promotor of Scheme: Buckingham Wealth Ltd (BWL) (incorporated in Belize) / Minerva Services Ltd (MSL) (incorporated in Belize)
- Address: Buckingham Wealth Ltd (Belize), No. 1 Orchid Garden Street, Belmopan, Belize / Minerva Services Ltd (Belize), PO Box 445, Suite 5, Garden City Plaza, Mountainview Boulevard, Belmopan, Belize
- Publication Date: 3 May 2023
- HMRC’s Scheme Description (summary): “Under the Umbrella Remuneration Trust (URT) arrangements, a scheme user (for example a company or a self-employed person) contributes to an offshore remuneration trust and claims the contribution as a deductible Corporation Tax or Income Tax expense. The money claimed to have been contributed to the trust is subsequently transferred, typically via another company, to the company’s director or back to the self-employed person. The director claims the funds received this way are held as ‘loans’ or held in a fiduciary capacity. HMRC has determined that these amounts are subject to tax, and recent tribunal decisions for the corporate users support this”.
- Any other information HMRC considers relevant to publish about these schemes: “We have published a document that shows BWL and MSL (the ‘Promoters’) encouraging URT users to sign a declaration that claims the URT to which contributions were made is void, and HMRC must close its enquiries as they are invalid, and instead make a ‘replacement’ contribution to a newly founded ‘Nova’ Trust. HMRC considers this to be an acknowledgement by the Promoters that the URT arrangements do not work. The enquiries remain valid and HMRC considers that the Nova Trust arrangements are a continuation of the arrangements used by the URT, and therefore subject to tax and NICs. HMRC would encourage all users of the URT not to enter into Nova without obtaining independent advice”.
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