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

The FTT refused the Employers’ appeals, and MLT’s appeals against the scheme sanction charges, finding that (a) the market value of the IP involved in some of the Pension Funding Deals was nil or negligible, and (b) the Employers had failed to meet their burden of proof in relation to other Pensions Funding Deals. Grounds 1 to 4 of MLT’s appeal to this Tribunal seek to challenge some of those findings.

The FTT also held that MLT’s applications to be discharged from liability to the scheme sanction charges relating to the unauthorised payments made to Prisym, Formwise and Langford were made after the statutory time limit. Grounds 5 and 6 set out MLT’s challenges to those findings.

The FTT went on to consider MLT’s appeal against HMRC’s refusal to discharge it from the scheme sanction charge in relation to Ballards, Criticall and Gannon, and agreed with HMRC. MLT’s appeal against that finding is considered under Grounds 7 and 8.