The Commissioners for HM Revenue and Customs v Mr Neil pickles and Mrs Sharon Pickles (Cross Appeals) : [2022] UKUT 00253 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Bacon and Judge Ramshaw on 20 September 2022

Read full decision in HMRC v Mr Neil pickles and Mrs Sharon Pickles UT-2020-000268 UT-2020-000269 UT-2021-000092 UT-2021-000093Cross appeals final decision

Income Tax – deemed distribution s 1020 Corporation Tax Act 2010 – Interpretation ‘market value’ – Correct approach to determining market value of benefit received - What constitutes ‘new consideration’. HMRC appeal allowed, taxpayers’ cross appeals dismissed.

Updates to this page

Published 20 September 2022