The Upper Tribunal (Tax and Chancery Chamber) has handed down its decision in Revenue & Customs Commissioners v Bella Figura Ltd [2020] UKUT 120 (TCC). The appeal and cross-appeal concerned the taxation of pension schemes and, specifically, HMRC’s powers to levy tax charges for unauthorised payments and the exercise of the First-tier Tribunal’s power to discharge those tax charges. The Tribunal allowed HMRC’s appeal, holding that a scheme sanction charge stood as a valid assessment, but partially allowed Bella Figura Ltd’s cross-appeal, setting aside HMRC’s assessments of an unauthorised payments charge and surcharge as being out of time, but upholding the scheme sanction charge. Daniel Burton acted for Bella Figura Ltd in this case.

You can read the judgment here.