Income Tax – registered pension scheme – unauthorised payment charge – scheme funds invested at taxpayer’s direction in preference shares of finance company as part of arrangement providing for loan from third party lender – payment made ‘under or in connection with’ investment in preference shares – Finance Act 2004, ss 161(3) and (4) – HMRC amending taxpayer’s return and imposing unauthorised payment charge and unauthorised payment surcharge on loan – Sections 209, 268 and 269 Finance Act 2004 – whether surcharge not ‘just and reasonable’ in all the circumstances and whether relief should be granted under s 268(3) Finance Act 2004 – no – appeal dismissed
Citations:
[2019] UKFTT 232 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 26 October 2022; Ref: scu.637841