12 January 2017
UT Decision: Mark Danvers v HMRC
INCOME TAX – registered pension scheme – scheme funds invested at member’s direction in preference shares of finance company – finance company lending its assets to third party lender who made loan to scheme member – scheme member obliged as condition of receiving loan to ensure scheme assets remain invested in finance company preference shares – whether loan to scheme member was unauthorised member payment -whether payment made in connection with the investment in the preference shares – ss 161 (3) and (4) Finance Act 2004
Laura Poots, Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents.
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