13 February 2015

UT Decision: Scotts Atlantic Management Ltd v HMRC

David Yates KC

Call: 2004 | Silk: 2019

Corporation Tax: (1) Sch 24 FA 2003 – whether the deduction 5 which would arise under a scheme which included a transfer of value occasioned by the grant of an option was “in respect of” an employee benefit contribution; (ii) section 74 TA 88: whether expense of contributions under the scheme was wholly and exclusively for the trade – had the FTT treated an incidental effect as a purpose.

Andrew Thornhill QC & Edward Waldegrave acted for the Appellants.
David Yates (led by Richard Coleman QC) acted for HMRC.

Click here for the full decision.