IFM36316 - Disguised fees: Condition 2 - A management fee arising to the individual (from 22 October 2015 onwards): Overview
Condition 2 - A management fee arising to the individual (from 22 October 2015 onwards)
ITA07/S809EZA(3)(c)
ITA07/S809EZDA - S809EZDB
The second condition for a sum to be a disguised fee is that under the arrangements a management fee must 바카라 사이트˜arise바카라 사이트™ to the individual in the tax year.
The requirements for Condition 2 were slightly different prior to 22 October 2015 (IFM36351), as from 22 October 2015, there is legislation (ITA07/S809EZDA and ITA07/S809EZDB) which defines when a management fee arises to other persons or connected companies. Prior to 22 October 2015 a management fee had to arise 바카라 사이트˜directly바카라 사이트™ or 바카라 사이트˜indirectly바카라 사이트™ to an individual.
If the sum you are considering has arisen prior to 22 October 2015 you should refer to IFM36351.
Dropping of the concept of 바카라 사이트˜directly or indirectly바카라 사이트™
The concept of whether a sum has arisen 바카라 사이트˜directly or indirectly바카라 사이트™ from a scheme does not apply from 22 October 2015.
In the majority of cases the addition to the legislation will not change the effect of the previous wording. The legislation still seeks to draw a line between genuine corporate management vehicles and more passive structures which are put in place to gain a tax advantage in relation to their disguised fee.