The case of AD Bly Groundworks and Civil Engineering Ltd & Anor v HMRC [2025] EWCA Civ. 1443 concerned two companies that implemented an unfunded unapproved retirement benefit scheme (UURBS) on the advice of their accountants. The scheme had been disclosed under the UK DOTAS (Disclosure of Tax Avoidance Schemes) regime and involved making unfunded promises to pay future pensions to directors and key employees. These promised pension amounts were deducted for corporation tax purposes.
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