Decision Number: | TC 08475 |
Appellant: | CIA INSURANCE SERVICES LTD |
Respondent: | Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Jeanette Zaman |
Date Of Decision: | 04/05/2022 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | CORPORATION TAX, INCOME TAX and NICs - Appellant resolved to make contributions to a remuneration trust - whether expenses incurred wholly and exclusively for the purposes of the Appellant's trade - whether contributions were taxable as diverted remuneration - whether payments made to individuals who were both indirect shareholders and employees of Appellant were within Part 7A ITEPA 2003 - held - expenses not deductible -“Part 7A applies and the payments are earnings with the exception of one contribution |