Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Contributions are taxable

02 December 2014
Issue: 4480 / Categories: Tax cases , Employees , Income Tax , Investments , Pensions

N S Philpott, D W Scott Law, D J McKillop, J B Law & V A Law (TC3969)

The taxpayers were directors of a company that set up a funded unapproved retirement benefits scheme (FURBS) in February 2006.

The business made a £34 000 cash contribution into the scheme on behalf of each director and transferred three parcels of development land.

The scheme paid lump sum tax-free payments of £3m £150 000 and £250 000 to three of the directors on their retirement in autumn 2006. It then became insolvent and was dissolved.

HMRC made an enquiry into the taxpayers’ returns which led to closure notices that increased the individuals’ taxable incomes to take into account the contribution of land to the FURBS. The Revenue ruled that the value of the properties should be divided equally between the taxpayers in accordance with ITEPA 2003 s 388.

The taxpayers appealed on the ground the transfer of property to the scheme had been not been made...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon