Corporation tax – Whether payments to employee benefit trusts deductible in computing profits – Whether tribunal had jurisdiction to consider issues of estoppel or legitimate expectation – Whether HMRC should be barred from defending appeal on grounds of delay – Applicability of Finance Act 1989 (FA 1989), s. 43 and Finance Act 2003 (FA 2003), Sch. 24.
The First-tier Tribunal very largely dismissed the taxpayer companiesʼ appeals in respect of deductibility of contributions made to the EBTs (employee benefit trusts) respectively established by them.
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