HMRC (Appellant) v M R Currell Ltd (Respondent)
Tuesday 24 – Wednesday 25 March 2026
By Appellant’s Notice filed on 21 March 2025 the Appellant, HMRC, appeals a decision of the Upper Tribunal (Tax Chamber), delivered on 6 December 2024 following a hearing on 15 and 16 October 2024.
The Respondent had paid money into an Employee Benefit Trust, which then loaned the funds to a director. The First‑tier Tribunal held that this created taxable earnings under the Social Security Contributions and Benefits Act 1992.
The Upper Tribunal disagreed, holding that the director received a loan, repayable, not remuneration. The Upper Tribunal therefore found no taxable earnings and allowed the Respondent’s appeal. HMRC’s application for permission to appeal was refused by the Upper Tribunal.
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Day 1
Day 2