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Conclusions
Conclusion
In conclusion, I would dismiss the appeal. The UT correctly upheld the FTT’s decision that deductions for the provisions in the Appellants’ accounts were disallowed by s.54 CTA 2009. If it were necessary to decide the point, I would also conclude that HMRC’s attempt in the alternative to rely on s.1290 would fail.
LordJustice Cobb:
I agree.
Lord Justice Newey:
I also agree.
- Heading
- Lady Justice Falk Introduction
- The facts
- The FTT and UT decisions
- The Grounds of Appeal and Respondent’s Notice
- Expenses not wholly and exclusively for trade and unconnected losses
- Section 1290 CTA 2009
- Employee benefit contributions
- Making of “employee benefit contributions”
- Restriction of deduction for non-contributory provision
- Conclusions