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Frank Hudson Transport Ltd v HMRC

In Frank Hudson Transport Ltd v HMRC (TC00758 – 8 November) a family company (F) purchased two cars from a finance company under a hire-purchase agreement and made them available to its controlling directors. HMRC issued a ruling that income tax was chargeable under ITEPA 2003 s 114.

The First-Tier Tribunal dismissed F’s appeal on this point holding that the cars had been ‘made available’ within s 114. F had also hired an executive box at a League One football club. The son of F’s controlling directors played for the club. HMRC issued a ruling that this was a benefit in kind for the directors and that income tax was chargeable under ITEPA 2003 s 203. F appealed contending that the box had been hired to entertain customers and that the directors did not need to hire the box in order to see their...

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