[2004] EWCA Civ 22.

Court of Appeal (Civil Division).

[The appeal against this decision is reported at [2005] BTC 355.]

Jonathan Parker and Potter L JJ and Charles J.

Judgment delivered 28 January 2004.

Income tax – Employment – Emoluments – ‘Potential emoluments’ – Employee benefit trust (EBT) set up for benefit of director-shareholders of company – Whether payments into EBT deductible – Whether contributions to EBT held by trustees with a view to their becoming relevant emoluments – Whether deductibility of payments postponed until emoluments paid – Income and Corporation Taxes Act 1988, s. 154Finance Act 1989, s. 43(11).

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