Upper Tribunal Tax and Chancery Chamber

UT/2022/000023 - [2024] UKUT 00104 (TCC)

Fecha: 06-Dic-2023

Heading

Neutral Citation: [2024] UKUT 00104 (TCC)

Case Number: UT/2022/000023

UPPER TRIBUNAL

(Tax and Chancery Chamber) The Royal Courts of Justice, Rolls Building, London

CORPORATION TAX – whether provisions in company’s accounts in respect of liabilities to make future pension payments were deductible expenses incurred wholly and exclusively for the purposes of a trade – whether deductions excluded under section 1290 Corporation Tax Act 2009 – appeal dismissed

Heard on: 6 December 2023

Judgment date: 22 April 2024

Before

JUDGE THOMAS SCOTT

JUDGE ASHLEY GREENBANK

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

Representation:

For the Appellants: Andrew Thornhill KC and David Welsh, instructed by Charterhouse (Accountants) Limited

For the Respondents: Rebecca Murray, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

DECISION