In M Danvers v HMRC [2016] UKUT 569 (10 January 2017) the UT found that a loan fell within FA 2004 s 161(3) and (4) as it had been made to the taxpayer in connection with an investment made by his self-invested pension scheme (SIPP).
Mr Danvers was 41 at the relevant time; below the statutory age at which he was entitled to take benefits from his pension fund without incurring an income tax charge. He decided to transfer his existing pension funds with Windsor Life and Winterthur Life to the HD SIPP a registered pension scheme and to take out a loan. The loan agreement stated that as a condition of the loan Mr Danvers must transfer his existing pension funds to HD SIPP and that after the payment of fees the remaining monies should be used to buy...
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In M Danvers v HMRC [2016] UKUT 569 (10 January 2017) the UT found that a loan fell within FA 2004 s 161(3) and (4) as it had been made to the taxpayer in connection with an investment made by his self-invested pension scheme (SIPP).
Mr Danvers was 41 at the relevant time; below the statutory age at which he was entitled to take benefits from his pension fund without incurring an income tax charge. He decided to transfer his existing pension funds with Windsor Life and Winterthur Life to the HD SIPP a registered pension scheme and to take out a loan. The loan agreement stated that as a condition of the loan Mr Danvers must transfer his existing pension funds to HD SIPP and that after the payment of fees the remaining monies should be used to buy...
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