Tax correctly charged

The John Mander pension scheme created in September 1987 had three original trustees: M EM and AJ a Revenue-approved pensioneer trustee. DJT Trustees replaced AJ as pensioneer trustee in 1994. M and EM resigned two years later and LTC Ltd was appointed in their place.

The funds of the scheme were transferred to the pension scheme for VSL a company owned by M and EM. DJT resigned as trustee in 1997 followed by LTC. The new trustees were EM and TMT Ltd.

HMRC wrote to EM and TMT giving notice that approval of the John Mander scheme was to be withdrawn with effect from November 1996. EM resigned as trustee in February 1998 and LTL was appointed.

The Revenue wrote again in April 2000 giving notice of withdrawal of approval and this time addressing the letter to LTL. The...