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Sippchoice (TC5217)
Sanctions for unauthorised payments
Sippchoice Ltd operated a self-invested personal pension scheme (SIPP) Sippchoice Bespoke SIPP. HMRC alleged that it was used as a pension liberation vehicle by allowing members to invest their funds in Imperium Enterprises Ltd which then allowed members to access the funds indirectly in the form of loans before they reached the age of 55.
HMRC argued that the loans were unauthorised member payments for the purposes of FA 2004 s 160(2). It imposed an unauthorised payments charge under s 208 on the scheme members and scheme sanction charges on the taxpayer.
The taxpayer appealed on the basis that it reasonably believed that no unauthorised payments had been made. It said it had no knowledge of the fact that loans had been made to individuals in...
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