Payments made under a ‘remuneration trust’ arrangement for the benefit of a company’s sole shareholder and director were not taxable as earnings from employment or under the ‘disguised remuneration’ provisions.

The appellant company (MDPL) operated a dental practice in which its sole shareholder and director (MT) provided his dental services. MDPL established a ‘remuneration trust’ (RT) which was stated to be for the benefit, broadly, of persons who had provided or might in the future, provide services, custom or products to MDPL.