Philip Manduca v The Commissioners for Her Majesty's Revenue and Customs

JurisdictionUK Non-devolved
Judgment Date26 May 2015
Neutral Citation[2015] UKUT 0262 (UTTC)
AppellantPHILIP MANDUCA
Respondent
CourtUpper Tribunal (Tax and Chancery Chamber)
Appeal NumberFTC/002/2014
[2015] UKUT 0262 (UTTC)
Appeal number: FTC/002/2014
Income tax – Appeal against closure notice – “Investment bonus” to be paid
to hedge fund managers in connection with the transfer of management of
the hedge fund from one company to another – Whether payment within Schedule
D Case VI – In the circumstances, yes – Appeal dismissed
UPPER TRIBUNAL
TAX AND CHANCERY CHAMBER
PHILIP MANDUCA Appellant
- and -
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS
Respondents
TRIBUNAL:
The President of the Upper Tribunal Tax and
Chancery Chamber
Sitting at the Rolls Building, Fetter Lane, London WC1A 2EB on 5 May 2015
Charles Bradley instructed by Graham Taylor for the Appellant
Jonathan Bremner instructed by the General Counsel and Solicitor to HMRC,
for the Respondents
© CROWN COPYRIGHT 2015

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