[2010] UKFTT 263 (TC)

[The appeal against this decision is reported at [2012] BTC 1,501.]

Sir Stephen Oliver QC (Chairman), Mike Bell ACA CTA

Decision released 11 June 2010

Corporation tax – capital or income – lump sum receipt – taxpayer a financial intermediary – taxpayer enters into exclusivity agreement with life insurance provider – life insurance provider agrees to pay lump sum in advance plus commission on sales following successful introductions from taxpayer – whether lump sum of capital nature – no – appeal dismissed

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