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You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> STRATEGIC BRANDING LIMITED v Revenue & Customs (CORPORATION TAX, INCOME TAX AND NICs - payments to a remuneration trust and loans to director of the Appellant) [2021] UKFTT 474 (TC) (01 December 2021) URL: https://www.bailii.org/uk/cases/UKFTT/TC/2021/TC08348.html Cite as: [2021] UKFTT 474 (TC) |
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Decision Number: | TC 08348 |
Appellant: | ![]() ![]() ![]() |
Respondent: | Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Jeanette Zaman |
Date Of Decision: | 01/12/2021 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | CORPORATION TAX, INCOME TAX AND NICs - payments to a remuneration trust and loans to director of the Appellant - whether contributions to trust made wholly and exclusively for the purposes of the Appellant-™s trade - whether HMRC made a discovery - whether amounts lent to director were taxable under Part 7A ITEPA 2003 or as earnings - held that discovery assessments were validly issued, contributions to trust were not deductible and amounts loaned were not earnings but were taxable under Part 7A - appeal dismissed |