Aspect Capital Limited v The Commissioners for HM Revenue and Customs: [2014] UKUT 0081 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Sinfield on 19 February 2014.
Read the full decision in .
CORPORATION TAX 鈥� deemed charge under section 419(1) ICTA 1988 on loans to participators 鈥� whether company made loan to employees under employee share scheme - yes 鈥� whether company made an advance to employees under scheme - no 鈥� whether employees incurred a debt under scheme 鈥� yes 鈥� whether debt has any value before occurrence of contingent event 鈥� yes - appeal dismissed.
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Published 1 December 2016