Business transactions, beneficial title and resulting trusts: the meaning of “payment” within the unauthorised payments charge regime – Wilberforce Chambers
‘In the recent Court of Appeal (“CA”) decision of Clark v HMRC [2020] EWCA Civ 204 (“Clark”) the Court gave valuable guidance as to the meaning of “payment” for the purpose of the imposition of the tax charge on unauthorised member payments from registered pension schemes under sections 208-210 of the Finance Act 2004 (“FA 2004”).’
Wilberforce Chambers, 11th May 2020
Source: www.wilberforce.co.uk