Gareth Clark v The Commissioners for HM Revenue and Customs: [2018] UKUT 0397 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Arnold and Judge Herrington on 26 November 2018.
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.Income tax – pension scheme – unauthorised payments charge – scheme to extract funds from SIPP and to provide member with access to funds by loans and investment management – whether transfer to trust which was void for uncertainty was an unauthorised member payment – whether payment was within scope of discovery assessment.