PSI5.3.6 - Contributions by Employers: Special Contributions - Kelsall v Investment Chartwork Limited

(This archived guidance relates to HMRC discretionary practice before the 6th April 2006. For current guidance on Registered Pension Schemes see the Registered Pension Schemes Manual)

In the tax case of Kelsall v Investment Chartwork Limited a judgement was given in the High Court on 14 May 1993 that the General Commissioners do not have the power to set aside a direction made by the Revenue under section 592(6) ICTA 1988 (formerly section 21(3)(b) FA70) to spread tax relief on a contribution.

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