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First-tier Tribunal (Tax)
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> STRATEGIC BRANDING LIMITED v Revenue & Customs (CORPORATION TAX, INCOME TAX AND NICs - payments to a remuneration trust and loans to director of the Appellant) [2021] UKFTT 474 (TC) (01 December 2021)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2021/TC08348.html
Cite as: [2021] UKFTT 474 (TC)
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| Decision Number: | TC 08348 |
| Appellant: | STRATEGIC BRANDING LIMITED |
| Respondent: | Her Majesty's Revenue & Customs |
|
Chairmen / Special Commissioners: |
Jeanette Zaman |
| Date Of Decision: | 01/12/2021 |
| Main Category: | PROCEDURE |
| Main Subcategory: | Other |
| Notes: | CORPORATION TAX, INCOME TAX AND NICs - payments to a remuneration trust and loans to director of the Appellant - whether contributions to trust made wholly and exclusively for the purposes of the Appellant-™s trade - whether HMRC made a discovery - whether amounts lent to director were taxable under Part 7A ITEPA 2003 or as earnings - held that discovery assessments were validly issued, contributions to trust were not deductible and amounts loaned were not earnings but were taxable under Part 7A - appeal dismissed |