[2014] UKUT 0081 (TCC)

Upper Tribunal (Tax and Chancery Chamber)

Mr Justice Warren, Chamber President, Judge Greg Sinfield.

Decision released 19 February 2014.

Corporation tax – Deemed charge under Income and Corporation Taxes Act 1988 (‘ICTA 1988’), s. 419(1) on loans to participators – Whether company made loan to employees under employee share scheme – Yes – Whether company made an advance to employees under scheme – No – Whether employees incurred a debt under scheme – Yes – Whether debt has any value before occurrence of contingent event – Yes – Appeal dismissed.

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