![UT/2024/000105 - [2025] UKUT 00212 (TCC)](https://backend.juristeca.com/files/emisores/logo_ICfrj4g.png){kind=logo}
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Neutral Citation: [2025] UKUT 00212 (TCC)
Case Number: UT/2024/000105
UPPER TRIBUNAL
(Tax and Chancery Chamber)
Rolls Building
Fetter Lane
London
EC4A 1NL
Heard on:11 April 2025
Judgment date: 30 June 2025
Income Tax – Business Investment Relief – meaning of ‘extraction of value’ in s809VH(2) Income Tax Act 2007 – whether director’s loan account was extraction of value - appeal dismissed
Before
MR JUSTICE MARCUS SMITH
JUDGE GREG SINFIELD
Between
BENOIT D’ANGELIN
Appellant
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Michael Firth KC instructed by McGrath Elliott LLP
For the Respondents: Rebecca Murray, counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs
DECISION