Background facts
Background facts
On 7 May 2002, the Company was incorporated. The Appellant was the sole shareholder from 1 May 2003; as well as the sole director from 21 November 2005, until the Company was dissolved on 9 September 2020.
On 21 January 2005, the Appellant and the Company signed the Assignment Agreement.
On 2 October 2008, Adler Shine (“Adler”), the Appellant’s representatives, wrote HMRC and confirmed that income from “Dunlop Slazenger”, and other related income, was reported in the Company.
The Agreements
The Appellant entered into several sponsorship agreements.
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