Tax

M R CURRELL LTD v Revenue & Customs (INCOME TAX AND NICs - PAYE- payment of �800,000 to an EBT)

[2023] UKFTT TC TC08855First-tier Tribunal (Tax)2023

Get the AI brief for this case

Generate a structured brief — facts, issues, held, reasoning, and significance — for this case in seconds. Or browse the verbatim judgment via the source links below.

Quick orient — first passages from judgment

INCOME TAX AND NICs - PAYE- payment of �800,000 to an EBT - loan of same amount made to a director of the appellant �real loan, secured with genuine repayment obligation - inevitable that at the time the payment was made to the EBT it would be lent to the director� - substantial reason for the payment was to enable the EBT to make the loan - was the loan a reward or benefit? - yes - why was it paid - for the exertions of the director - loan was earnings within s 62 ITEPA - payment to EBT taxable - appeal dismissed

For the Appellant:�� Ben Elliott of counsel instructed by Haslers Business Services LLP

For the Respondents: �� Edward Waldegrave of counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs

             In relation to the company for the tax year ended 5 April 2011, the respondents (or � HMRC �) have made the following :�

(1)           A determination dated 15 March 2015 issued under regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003 in the sum of �320,000; and

Auto-extracted from BAILII. Full structured brief in progress — the source links below give you the verbatim judgment in the meantime.

Read the full judgment elsewhere

Multiple official and mirror sources — pick whichever loads cleanly on your network.

More Tax cases

Ferguson & Anor v Revenue and Customs (STAMP DUTY LAND TAX - residential property - whether paddock was part of garden or grounds of dwelling - paddock was part of grounds)

[2026] UKFTT TC 238

MWL International Ltd & Anor v Revenue and Customs (NATIONAL INSURANCE CONTRIBUTIONS - agreement with inspector of taxes that certain cars would be "pooled cars" for NICs purposes if various conditions satisfied - HMRC subsequently sought to collect NICs retrospectively - whether HMRC estopped from doing so - whether the FTT had jurisdiction to decide whether Appellants had legitimate expectation that decisions would not be retrospective)

[2026] UKUT TCC 62

BGC Services Holdings LLP v Revenue and Customs (Determinations under Reg 80 of the PAYE Regs - whether it appeared to HMRC that there may be tax payable)

[2026] UKFTT TC 558

Best Cosmetics Ltd v Revenue and Customs (IMPORT VAT - Postponed VAT Accounting - importer not VAT registered - post-clearance demand notices issued for unpaid VAT - no evidence that postponed VAT was accounted for)

[2026] UKFTT TC 236

Nwaneri v Revenue and Customs (Income tax - Expenses incurred in the performance of duties of employment - Travel expenses - Subsistence expenses - Whether deductible - Penalties - Whether behaviour deliberate)

[2026] UKFTT TC 581

Ivey v Revenue and Customs (Strike Out - Jurisdiction)

[2026] UKFTT TC 233

Common Room

Discussion

0 comments · About the Common Room →

No comments yet — start the discussion.

Voted-best comments help future students and feed Caselaw's AI study tools.

This case is reproduced verbatim from the public judgment published by The National Archives under the UK Government's Open Government Licence v3.0. If you appear in this case and believe it should not be published — for example because your conviction was quashed on appeal, you have statutory anonymity, or for other privacy reasons — request removal here.

Tax