The First-tier Tribunal has handed down its Decision in The Vaccine Research Limited Partnership v HMRC [2025] UKFTT 402 (TC).
The case concerned whether payments made under circular financing arrangements gave rise to tax charges under sections 683 (annual payments) or 687 (income not otherwise charged) Income Tax (Trading and Other Income) Act 2005.
The FTT held, applying the Ramsay principle of statutory interpretation, that the payments were not chargeable to income tax and allowed the taxpayer’s appeal.
Jonathan Bremner KC and James MacDonald KC appeared for the taxpayer, instructed by Taylor Wessing LLP.
A copy of the Decision can be found here.