Rory Mullan QC appeared for the taxpayer in its appeal concerning whether a corporation tax deduction was available in respect of a provision made following an agreement to pay to pensions to certain employees. The FTT dismissed the appeal on the basis that one of the purposes of the provision was to obtain a tax deduction. It agreed, however, the employee benefit contribution anti-avoidance rules were not engaged.
A copy of the decision can be found HERE.
