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Decision Number: |
TC 08679 |
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Appellant:
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WIRED ORTHODONTICS LIMITED
IAN HUTCHINSON
SUSAN BESSANT
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Respondent:
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Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Tracey Bowler
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Date Of Decision:
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06/01/2023 |
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Main Category:
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PROCEDURE |
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Main Subcategory:
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Other |
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Notes:
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Tax avoidance scheme – purchase of gold for employees who met the cost thereof through sale proceeds, creating credits in directors’ loan accounts alongside an obligation taken on by the directors to satisfy the company’s undertaking to make payment in the future to an EBT – whether earnings – s62 ITEPA – Rangers applied - whether deductible expenses for the company – correct treatment under GAAP - wholly and exclusively for the purposes of the trade – Vodaphone applied.
Procedure – application to admit further evidence; application to admit a new ground of appeal.
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Decision(s) to Download:
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TC08679 AMENDED.pdf 
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