Abstract: | This case concerned a remuneration trust which had been establishedby a company called DSL in April 2000. The beneficiaries ofthe Trust were named as the past, present and future employeesof DSL and their families. The shares in DSL were owned by acouple, Mr and Mrs L, who were also the two directors of DSL.The Trust assets comprised the proceeds of sale of the businessof DSL and its interest in two retail shops, and representedthe bulk of the assets of Mr and Mrs L and their family. The terms of the Trust prevented any outright distribution orpayments being made or any benefits |