25 April 2023

Morgan Lloyd & Ors -v- HMRC

The FTT has released its decision in this case concerning finance provided from pension schemes to employers, backed by a range of intellectual property assets.  The FTT determined a number of issues, including identifying and valuing the intellectual property in several test cases.  The FTT concluded that a number of unauthorised payments had been made, and that the scheme administrator’s liability for the resulting tax charges should not be discharged.

Laura Poots, acting for HMRC, led Emile Simpson, together with Jamie Muir Wood of Hogarth Chambers and Sarah Black of 11 New Square.

To view a copy of the decision please click here