Income tax

The two loans made to the taxpayer company by an occupational pension scheme, of which the taxpayer had been the principal employer, had not complied with the conditions set out in s 179 of the Finance Act 2004 in order to be treated as authorised employer loans.

Accordingly, they gave rise to unauthorised payments and charges under ss 208 and 209 of the Act. The First-tier Tribunal (Tax Chamber) so held in dismissing the taxpayer’s appeal against the notices of assessment issued against it by the Revenue and Customs Commissioners in respect of those unauthorised payments.