FTT upholds assessments for unauthorised payments in relation to pension funding

Sarah Black 11 New Square

” The FTT has determined in these test cases that transactions entered into by a number of companies to access finance from their respective pension funds were unauthorised payments as the IP assets the transactions were based on (either loans secured over the assets or sales of the assets with a lease/licence back) did not have the value attributed to them. The tribunal also upheld scheme sanction charges against the scheme administrator.


Sarah Black acted for HMRC led by Laura Poots (Pump Court Tax Chambers), alongside Jamie Muir Wood (Hogarth Chambers) and Emile Simpson (Pump Court Tax Chambers). The decision can be found here Morgan Lloyd Trustees Limited (and others) v HMRC [2023] UKFTT 355 (TC)