MORGAN LLOYD TRUSTEES LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS : [2025] UKUT 00102 (TCC)
Upper Tribunal Tax and Chancery decision by MR JUSTICE MELLOR and JUDGE ANNE REDSTON on 25 March 2025
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INCOME TAX – pensions – unauthorised payments – scheme sanction charges – contractual interpretation – what is meant by “the commercial context” – challenges to the FTT’s findings of fact and evaluative judgments – time limit for making an application to be discharged from the scheme sanction charge – appeal allowed in part
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Published 25 March 2025