25 February 2014
UT Decision: Aspect Capital Ltd v HMRC
CORPORATION TAX – deemed charge under section 419(1) ICTA 1988 on loans to participators – whether company made loan to employees under employee share scheme – yes – whether company made an advance to employees under scheme – no – whether employees incurred a debt under scheme – yes – whether debt has any value before occurrence of contingent event – yes – appeal dismissed
Richard Vallat was instructed by HMRC.
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