Source: All England Reporter
Publisher Citation: [2013] All ER (D) 205 (Dec)
Neutral Citation: [2013] EWCA Civ 1683
Court: Court of Appeal, Civil Division

Lord Justice Moses, Lord Justice Patten and Lord Justice Beatson

Representation Laurent Sykes (instructed by Ansons LLP) for the appellant.
  Akash Nawbatt (instructed by Revenue and Customs Commissioners) for the Revenue.
Judgment Dates: 19 December 2013


Pension - Pension schemes - Retirement benefit scheme - Charge to tax on administrator of retirement benefit scheme on cessation of approval of scheme - Assessments issued in respect of tax year 2000/01 - Appellant trustee and administrator of scheme appealling - Whether assessments issued in respect of correct tax year - Income and Corporation Taxes Act 1998, ss 591A(2), 591B(1), (2), 591C(1), 591D(7).

The Case

Pension Pension schemes. The appeal concerned whether the Revenue and Customs Commissioners (the Revenue) had assessed the appellant for tax in the wrong year. The First-tier Tribunal (Tax Chamber) and the Upper Tribunal (Tax Chamber) had concluded that the correct year of charge was tax year 2000-01. The appellant sought to establish that the correct tax year was 1996-97. The Court of Appeal, Civil Division, upon considering the correct application of relevant sections of the dismissed the appellant's appeal and upheld the earlier decisions.

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