13 February 2015
UT Decision: Scotts Atlantic Management Ltd v HMRC
Corporation Tax: (1) Sch 24 FA 2003 – whether the deduction 5 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.
Andrew Thornhill QC & Edward Waldegrave acted for the Appellants.
David Yates (led by Richard Coleman QC) acted for HMRC.
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