UT (Tax & Chancery) UT/2023/000103 - [2025] UKUT 00102 (TCC)

Fraser was an architectural hardware company. Its owner and managing director, Mr Kilmister, passed away before the FTT hearing [14]. On 18 June 2010, a SSAS – the Louis Fraser Pension Scheme – was set up with Mr Kilmister and MLT as trustees.

In July 2010, the SSAS loaned Fraser £30,000 on the security of its Domain Name, and in October 2010, the SSAS made a second loan, also secured on the Domain Name. Neither was part of the Pension Funding Deal considered by the FTT.

On 21 June 2012, a firm called Valuation Consulting Co Ltd (“Valuation Consulting”) provided a valuation of certain IP; the FTT’s findings as to the nature of that IP are challenged and we return to this under Ground 1. The amount of the valuation was £36,142. On 18 July 2012, the SSAS lent Fraser £23,000, secured by that IP.