24th Feb 2017
Summary: Payments made into employee benefit trusts had not been made wholly and exclusively for the purposes of the employers’ trades and were not deductible in computing profits for corporation tax purposes. The First-tier Tribunal did not have jurisdiction to consider arguments that HMRC was precluded from making corporation tax assessments by reason of estoppel and legitimate expectation.
Stephen Hackett, instructed by Griffin Law, for the Appellant
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