Aspect Capital Ltd v Revenue And Customs [2014] UKUT 81 (TCC) (19 February 2014)
CORPORATION TAX – deemed charge under section 419(1) ICTA 1988 on loans
to participators – whether company made loan to employees under employee share
scheme - yes – whether company made an advance to employees under scheme - no
– whether employees incurred a debt under scheme – yes – whether debt has any
value before occurrence of contingent event – yes - appeal dismissed
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