Provision for future payments under an unfunded retirement benefit scheme not wholly and exclusively for trade purposes.
In A D Bly Groundworks and Civil Engineering Ltd and another v HMRC [2024] UKUT 104 (TCC) (22 April 2024) the Upper Tribunal (UT) dismissed the companies’ appeals against a decision of the FTT that a deduction in computing trading profits was not allowable for provisions in respect of future payments under an unfunded unapproved retirement benefit scheme (UURBS).
Both taxpayers engaged the services of the same firm of chartered accountants to establish an UURBS under which they promised to provide directors and certain key employees with a pension in the future. The taxpayers made provisions in their accounts for their liability to make pension payments in future. The provisions were set at between 80% and 100% of the profits before tax for each period. The UURBS was notified to HMRC under the...
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Provision for future payments under an unfunded retirement benefit scheme not wholly and exclusively for trade purposes.
In A D Bly Groundworks and Civil Engineering Ltd and another v HMRC [2024] UKUT 104 (TCC) (22 April 2024) the Upper Tribunal (UT) dismissed the companies’ appeals against a decision of the FTT that a deduction in computing trading profits was not allowable for provisions in respect of future payments under an unfunded unapproved retirement benefit scheme (UURBS).
Both taxpayers engaged the services of the same firm of chartered accountants to establish an UURBS under which they promised to provide directors and certain key employees with a pension in the future. The taxpayers made provisions in their accounts for their liability to make pension payments in future. The provisions were set at between 80% and 100% of the profits before tax for each period. The UURBS was notified to HMRC under the...
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