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
Warren P J
[2014] UKUT 81 (TCC), [2014] STC 1360, [2014] BTC 508, [2014] STI 873
Bailii
England and Wales
Updated: 17 June 2021; Ref: scu.523482 br>