Ross Birkbeck has published an article in the Tax Journal. Please see below a brief overview of the article and the link to the article in full.
‘In a series of recent cases, HMRC has challenged companies which have claimed deductions for payments made in the context of tax planning on the basis that they are not deductible under CTA 2010 s 54. Often the payments are to reward employees, and HMRC simultaneously claims that they are taxable income in the hands of the employee.’
