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 Scotts Atlantic Management Limited and Others v The Commissioners for HM Revenue and Customs: [2015] UKUT 0066 (TCC).

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