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

The Appellants appealed to the First-tier Tribunal (Tax Chamber) (the “FTT”) against closure notices issued by the Respondents (“HMRC”) denying corporation tax deductions claimed by the Appellants in respect of certain liabilities relating to future pension payments. HMRC contended that the liabilities were not deductible because they were not incurred wholly and exclusively for the purposes of the Appellants’ respective trades, and, alternatively, because they were disallowed under section 1290 of the Corporation Tax Act 2009 (“CTA 2009”).

In a decision released on 26 November 2021 (the “Decision”) the FTT dismissed the appeals. The Appellants appeal against the Decision.