THE COMMISSIONERS FOR HIS MAJESTY鈥� S REVENUE AND CUSTOMS v MARLBOROUGH DP LIMITED [2024] UKUT 00103 (TCC) (Final Supplemental decision)
Upper Tribunal Tax and Chancery decision of Mr Justice Edwin Johnson and Judge Guy Brannan on 12 April 2024
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INCOME TAX 鈥� tax avoidance scheme 鈥� whether amounts paid by respondent under trust arrangements taxable as earnings from employment under s62 ITEPA 2003 鈥� whether taxable as earnings under Part 7A ITEPA 2003 because paid 鈥渋n connection with鈥� employment 鈥撯€� UT deciding that loan made 鈥渋n connection with鈥� directorship 鈥� draft UT decision circulated to parties 鈥� Respondent challenged the UT decision on the grounds of procedural unfairness 鈥� further hearing 鈥� held: no procedural unfairness 鈥� observations on need for the parties to make submissions on remaking or remitting 鈥�
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Published 17 April 2024