TC09595 - [2025] UKFTT 00894 (TC)
First-tier Tribunal (Tax Chamber)

TC09595 - [2025] UKFTT 00894 (TC)

Fecha: 12-Jun-2025

Facts

Facts

Corporate structure

9.

APL which was incorporated in 2004 was, until the end of March 2025, a subsidiary within a group of companies, the L3 Harris Group, that provides training to airline pilots. APL was 100% owned by L3 A&AT which itself was owned by L3 CTS. L3 A&AT was formed to acquire the business of CTC Aviation Group plc (“CTC”) which it did in May 2015 through the purchase of shares in CTC Aviation Holdings. APL was previously part of CTC, which included CTC McAlpine Ltd and Airline Recruitment Limited.

10.

Airline Recruitment Limited was the entity initially responsible for administering the Sponsored Training Programme, a role which was essentially taken over by APL following its incorporation.