Boyle v HM Revenue and Customs [2013] UKFTT 723 TC03103

The scheme, in question, was marketed by consulting Overseas Limited to independent contractors as a remuneration package. The idea was that it would save them considerable amounts in relation to both income tax and national insurance contributions.

To allow for tax avoidance, the contractors signed up as employees of the Isle of Man Company Sandfield consultants Ltd. They then agreed to accept two thirds of their income as loans in Romanian lei, Byelorussional roubles or Uzbekistani soums. They then entered into currency trades that were meant to turn this income into non-taxable foreign exchange gains.

The judge held that the loans where in both substance and reality income from his