References: [2014] UKUT 81 (TCC)
Links: Bailii
Coram: Warren P J
UTTC CORPORATION TAX – deemed charge under section 419(1) ICTA 1988 on loans to participators – whether company made loan to employees under employee share scheme – yes – whether company made an advance to employees under scheme – no – whether employees incurred a debt under scheme – yes – whether debt has any value before occurrence of contingent event – yes – appeal dismissed
