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Tax avoidance scheme - purchase of gold for employees who met the cost thereof through sale proceeds, creating credits in directors� loan accounts alongside an obligation taken on by the directors to satisfy the company�s undertaking to make payment in the future to an EBT - whether earnings - s62 ITEPA - Rangers applied - whether deductible expenses for the company - correct treatment under GAAP - wholly and exclusively for the purposes of the trade - Vodaphone applied.
Procedure - application to admit further evidence; application to admit a new ground of appeal.
For the Appellant:�������� Mr Andrew Thornhill KC, of counsel, instructed by Levy and Levy Solicitors
For the Respondents: �� Mr Adam Tolley KC and Mr Charles Bradley of counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs
             HMRC say that the Directors received money or money�s worth as a reward for the provision of the services which constituted �earnings� in relation to their employment with the Company, notwithstanding their obligation to pay sums to the Trust.� As a result HMRC say that:
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