Originally posted by PhilBreeze
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Our strategy allows for UK resident businesses to contribute to the trust and deduct such contributions from their taxable profits under the "wholly & exclusively" principle. The Sempra decision applies only to trusts set up to provide benefits to employees of the contributing companies, or their families. Contributions are reported on the Company Return as a deductable expense and have done for many years without further enquiry from HMRC.
Our insurance cannot cover tax liabilities, this would be non-compliant with MSC legislation, however as stated previously the fee reimursement leaves our clients with 100% of their money and the tax bill they would have had anyway, so the "risk free" claim is justified IMO?
Our insurance cannot cover tax liabilities, this would be non-compliant with MSC legislation, however as stated previously the fee reimursement leaves our clients with 100% of their money and the tax bill they would have had anyway, so the "risk free" claim is justified IMO?
If memory serves this guy was absolutely adamant that there was no risk from using his scheme and would not be convinced otherwise. Oh well 
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