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Miller's Tales III

 
Pete Miller National Tax Technical Director of Tenon writes about some more recent tax cases that have taken his interest. The theme this time is about the analysis of legal agreements and surrounding documents
TM Collins v HMRC SpC 00661
 
This case concerned a sale of shares by the shareholders including Mr Collins to a third party. Mr Collins wanted the majority of his share of the consideration to be paid into his pension fund. However if the company paid a pension contribution before being sold the value of all the shares would be reduced to the detriment of all the shareholders. And if Mr Collins merely paid a pension contribution out of the proceeds of...

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