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Upper Tribunal Tax and Chancery Chamber
UT (Tax & Chancery) UT/2023/000098 - [2024] UKUT 00404 (TCC)
Fecha: 16-Oct-2024
Error al cargar el documento
- Heading
- Introduction
- Relevant legislation
- FTT Decision
- Arrangements concerning the EBT
- Approach and conclusions of the FTT
- Ground of appeal
- FTT’s consideration of whether the Loan was a reward or benefit
- Appellant’s submissions
- Exercise of discretion under s12 TCEA 2007
- Reasoning of the FTT in the Decision
- Whether the Decision involved the making of an error of law at [33] to [37]
- Correct outcome on re-making the decision
- HMRC’s submissions
- Headline response to ground of appeal
- Facts as found by the FTT
- Legal principles relevant to test for earnings
- Reasoning of the FTT in the Decision
- Correct outcome on re-making the Decision
- Discussion and conclusion
- Whether the Decision involved the making of an error of law
- Conclusions