The Commissioners for HM Revenue and Customs v Mr Neil pickles and Mrs Sharon Pickles (Cross Appeals) : [2022] UKUT 00253 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Bacon and Judge Ramshaw on 20 September 2022
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Income Tax – deemed distribution s 1020 Corporation Tax Act 2010 – Interpretation ‘market value’ – Correct approach to determining market value of benefit received - What constitutes ‘new consideration’. HMRC appeal allowed, taxpayers’ cross appeals dismissed.
Published 20 September 2022