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13 May 2013

FTT Decision: Scotts Atlantic Management Ltd & ors v HMRC

Corporation tax  –  whether value contributed to Employee Benefit Trusts was deductible for corporation tax purposes  –  whether director was chargeable to income tax on benefits made available to him –  if there was a PAYE liability on the companies, whether that could be traced to the director under Regulation 72 –  whether the corporation tax deduction (if allowable on general principles) was denied by paragraph 1 Schedule 24 FA 2003 in the event that the benefits were not taxable as emoluments or earnings of the director  –  Corporation tax appeal dismissed  –   Income tax appeal allowed.

Andrew Thornhill QC & Edward Waldegrave, instructed by Scotts Atlantic Management Ltd, acted for the Appellants.

James Sheehan, counsel, on behalf of Mr. Dryburgh’s trustee in bankruptcy, Richard Coleman QC, James McClelland and David Yates, Counsel for the

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