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

On 13 February 2009, certain software owned by Prisym was valued by a local firm of accountants, Savile Consultancy Ltd (Footnote: ⁴) (“Savile”), at £300,000. On 13 May 2009, Prisym entered into a sale and licence back agreement with its SSAS, the Tech Pension Scheme [18].

Before the conclusion of the FTT hearing, the parties agreed the valuation as being £250,000. As a result of that agreement, the only issue decided by the FTT was whether MLT had applied in time for relief from the related scheme sanction charge [59]. The FTT’s finding on that issue is the basis for Grounds 5 and 6 of MLT’s appeal to this Tribunal, and we consider it later in our decision.