Tax

E.ON UK Plc v Revenue and Customs (INCOME TAX AND NATIONAL INSURANCE CONTRIBUTIONS)

[2021] UKFTT TC TC08125First-tier Tribunal (Tax)2021

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

Text Box: INCOME TAX AND NATIONAL INSURANCE CONTRIBUTIONS �- change to terms and conditions of the pension scheme - payment to employees - whether Tilley v Wales applied - replacement principle - whether payment �from� the employment - appeal refused

The hearing took place on 18 and 19 February 2021 by video.� A face to face hearing was not held because of restrictions caused by the pandemic.�

Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media and/or members of the public could apply to join the hearing remotely to observe the proceedings.� The hearing was therefore held in public.

Mr Charles Bradley of Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

E.ON UK plc (�E.ON�) is a well-known supplier of power and gas.� In mid-2018, some 1,100 of its employees were members of a �retirement balance� type of pension scheme. Under retirement balance schemes, a notional amount is accumulated each year, which can be used on retirement to provide a lump sum and/or to pay a pension.� The employee contributes to the notional amount by deduction from his salary, and the employer guarantees to make up the balance.�

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

Ivey v Revenue and Customs (Strike Out - Jurisdiction)

[2026] UKFTT TC 233

Revenue and Customs v Electric Mobility Euro Ltd & Anor (Discovery assessments - extended time limit assessments - penalty for inaccuracy in a return - deliberate inaccuracy - whether deliberate inaccuracy necessarily involves dishonesty - whether HMRC required to specifically plead and prove dishonesty - whether the FTT erred in failing to explain how the appellant's conduct might not involve dishonesty)

[2026] UKUT TCC 37

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