GR Solutions Ltd v Revenue & Customs [2012] UKFTT 234 (TC) (02 April 2012)

GR Solutions Ltd v Revenue & Customs [2012] UKFTT 234 (TC) (02 April 2012)

The car was made available to Mr Hall by the company by reason of his employment within the meaning of ITEPA s.114(1), and the fuel was provided for the car by reason of his employment under s.149(1); part-ownership does not remove the car from the benefit regime; the appeal is dismissed.

Citation
[2012] UKFTT 234
Parties
Appellant: G R Solutions Ltd; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
02 April 2012
Procedural Posture
Appeal / First Tier Tribunal (tax Chamber) Decision
Outcome
Appeal dismissed
Legal Topics
National Insurance Contributions, Car Benefit, Car Fuel Benefit, Employment Benefits, Income Tax (earnings and Pensions) Act 2003

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 2 Authorities cited 6 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

G R Solutions Ltd

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Appeal / First Tier Tribunal (tax Chamber) Decision

  1. 1 Whether the car was 'made available' to Mr Hall by the company by reason of his employment under ITEPA s.114(1)
  2. 2 Whether fuel was 'provided for a car by reason of an employee's employment' under ITEPA s.149(1)
  3. 3 Whether part-ownership by the employee affects liability for car and fuel benefit charges

Ratio Decidendi

The car was made available to Mr Hall by the company by reason of his employment within the meaning of ITEPA s.114(1), and the fuel was provided for the car by reason of his employment under s.149(1); part-ownership does not remove the car from the benefit regime; the appeal is dismissed.

Court Disposition

Appeal dismissed