Taxation of Directors and Employees Post the Supreme Court Decision in RFC 2012 Plc ("Rangers") and the 2017 Finance Acts

An Afternoon Seminar at The Law Society’s Hall, London WC2A

Wednesday October 18th 2017

Chairman: Robert Venables Q.C.

Speakers: Robert Venables Q.C., Harriet Brown and Setu Kamal.

 All the speakers are members of Old Square Tax Chambers, Lincoln’s Inn, WC2A 3UE, 020 7242 2744,

Fees £450 + VAT (£90), total £540.

 Early Bird price for bookings made before September 11th £400 + VAT (£80), total £480.

For booking and Terms and Conditions please visit or contact


In RFC 2012 Plc v Advocate General for Scotland, the Supreme Court has held that everyone (including, until 2015, HMRC itself and its predecessors) had completely misconstrued the income tax acts, since the imposition of modern income tax in 1842, and by “purposive construction” has purported to impose unjust charges to tax on directors and employees.

Many appear to have misunderstood the precise effect of the decision and consider it to have a wider impact than it does, even if correct and binding precedent.

The seminar will consider the precise scope of the decision and in which situations it will, even if binding precedent, and will not apply.

The seminar will also consider the profound changes made to the “Disguised Remuneration” rules made by Finance Act 2017 and the future changes proposed to be included in Finance Act No 2 2017 (as per the draft clauses published on July 13th with any amendments made in the passage of the autumn Finance Bill).

The seminar will further consider the current benefit in kind rules in the light of Finance Act 2017 changes.


13.30 Registration

14.00 Chairman’s Introduction followed by:

The Rangers Decision – Robert Venables Q.C.

What does the case decide? Is it internally consistent? Is it binding Precedent – It is compatible with other House of Lords and Supreme Court authorities? Even if binding, in what limited situations will the decision apply?

14.45 Benefits in Kind Post Finance Act 2017 – Harriet Brown

The Earnings Charge – ITEPA Part 3 BIK Charges Post Finance Act 2017 especially Employment-Related Loans (Chapter 7) and General Charge (Chapter 10) – BIK Charges Under ITEPA Part 7A (Disguised Remuneration)

15.25 Finance Act 2017 Changes to Disguised Remuneration – Robert Venables Q.C.

The additional heads of charge – New Perceived Anti-Avoidance Rules

16.05 Discussion Session with Refreshments

16.20 Finance (No 2) Act 2017 Retrospective Charge on April 5th 2019 – Setu Kamal

17.00 Panel Session and Questions to Speakers

17.30 Close of Seminar

For booking and Terms and Conditions please visit or contact


Email Us Call Us