Heading

ON APPEAL FROM THE UPPER TRIBUNAL (TAX AND CHANCERY CHAMBER)
JUDGE THOMAS SCOTT AND JUDGE ASHLEY GREENBANK
[2024] UKUT 00104 (TCC)
Royal Courts of Justice
Strand, London, WC2A 2LL
Before:
LORD JUSTICE NEWEY
LADY JUSTICE FALK
and
LORD JUSTICE COBB
Between:
(1) A D BLY GROUNDWORKS AND CIVIL ENGINEERING LIMITED (2) CHR TRAVEL LIMITED | Appellants |
- and – | |
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS | Respondents |
Andrew Thornhill KC and David Welsh (instructed by Morr and Co LLP) for the Appellants
Rebecca Murray (instructed by HMRC Legal Group) for the Respondents
Hearing date: 5 November 2025
Approved Judgment
This judgment was handed down remotely at 2.00pm on Friday 14 November 2025 by circulation to the parties or their representatives by e-mail and by release to the National Archives.
.............................
- 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
![CA-2024-001410 - [2025] EWCA Civ 1443](https://backend.juristeca.com/files/emisores/logo_Sjvxvlx.png)