On 24 February 2017, the First-tier Tribunal2 held, in respect of three cases heard together, that contributions made over a period of time to employee benefit trusts (EBTs) were not deductible for corporation tax purposes. In each case the Tribunal held that there was a duality of purpose to the making of the contributions. At least in part, the relevant company’s intention was to make funds available to a principal shareholder.

The decision can be viewed here.