Readers' forum : Swedish solution

My clients operate a tourism business through a UK limited company. However most of the duties for the company have been performed in Sweden where both husband and wife directors have been resident until now. They have not performed any duties in the UK but a board meeting can be arranged here if what follows suggests to readers that this may be appropriate.

The UK company is making employer contributions to a UK-registered personal pension scheme. My concern is whether FA 2004 s 189 precludes them from being deductible for corporation tax purposes. Alternatively does the fact that they are employer contributions allow FA 2004 s 196 to come to the rescue in this regard?

The directors are not resident in the UK now and nor have they been UK resident at any time in the past five tax years. They are in the process...