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John Mander Pension Trustees Ltd v CRC, Supreme Court, 29 July 2015
In April 2000 HMRC notified the administrator of the John Mander Ltd Directors Pension Scheme that approval under TA 1988 s 591B(1) was withdrawn with effect from 5 November 1996. In July 2000 they issued an assessment for 2000/01 under s 591C to the then administrator. In January 2007 a fresh assessment was raised against the new administrator.
The taxpayer appealed against both assessments on the ground that the tax related to 1996/97 when withdrawal of approval had taken effect. The First-tier Tribunal Upper Tribunal and Court of Appeal found against the taxpayer saying the tax was assessable in the year 2000/01 when the withdrawal was notified.
The taxpayer appealed.
Lord Sumption in the Supreme Court decided that according to s 591 tax was...
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