||All England Reporter
|| All ER (D) 80 (Jul)
|| UKFTT 533 (TC)
||UK First-tier Tribunal (Tax)
Judge Anne Scott
||Philip Simpson QC (instructed by Henderson Loggie) for the taxpayer.
||Elizabeth Roxburgh (instructed by General Counsel and Solicitor to the Revenue and Customs Commissioners) for the Revenue.
||28 June 2017
Income tax - Pension - Unauthorised payment surcharge
Income tax Pension. The taxpayer company's appeal against the imposition of certain charges on it following income tax assessments issued by the Revenue and Customs Commissioners, in respect of a loan made to the taxpayer from a pension fund, was dismissed by the First-tier Tribunal (Tax Chamber)(the FTT). The FTT held that in the circumstances, the payments comprising the loan did not satisfy the relevant statutory criteria set out in the and the taxpayer had failed to establish that it would not be just and reasonable for it to be liable to those charges.
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