Scotts Atlantic Management Limited and Others v The Commissioners for HM Revenue and Customs: [2015] UKUT 0066 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Hellier on 13 February 2015.
Read the full decision in .
Corporation Tax: (1) Sch 24 FA 2003 – whether the deduction which would arise under a scheme which included a transfer of value occasioned by the grant of an option was “in respect of” an employee benefit contribution; (ii) section 74 TA 88: whether expense of contributions under the scheme was wholly and exclusively for the trade – had the FTT treated an incidental effect as a purpose.
Published 1 December 2016