Aspect Capital Limited v The Commissioners for HM Revenue and Customs: [2014] UKUT 0081 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Sinfield on 19 February 2014.

Read the full decision in Aspect Capital Plc v The Commissioners for HM Revenue and Customs.

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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