The Commissioners for HM Revenue and Customs v Mr Neil pickles and Mrs Sharon Pickles (Cross Appeals)
| Jurisdiction | UK Non-devolved |
| Judge | Mrs Justice Bacon,Judge Ramshaw |
| Neutral Citation | [2022] UKUT 00253 (TCC),[2022] UKUT 00253 (TCC) |
| Subject Matter | 20 September 2022 |
| Court | Upper Tribunal (Tax and Chancery Chamber) |
| Published date | 20 September 2022 |
UT Neutral citation number: [2022] UKUT 00253 (TCC)
UT (Tax & Chancery) Case Numbers: UT-2020-000268
UT-2020-000269
UT-2020-000092
UT-2020-000093
Upper Tribunal
(Tax and Chancery Chamber)
Hearing venue: The Rolls Building, Fetter Lane, London EC4A 1NL
Heard on: 24 June 2022
Judgment date: 20 September
2022.
Income Tax – deemed distribution s 1020 Corporation Tax Act 2010 – Interpretation ‘market
value’ – Correct approach to determining market value of benefit received - What constitutes ‘new
consideration’. HMRC appeal allowed, taxpayers’ cross appeals dismissed.
Before
MRS JUSTICE BACON (Chamber president)
JUDGE PHYLLIS RAMSHAW
Between
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS
Appellants (and Respondents in cross appeal) and
MR NEIL PICKLES
MRS SHARON PICKLES
Respondents (and Appellants in cross appeal)
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