Income tax relief was available to self-invested pension scheme members for payments to the schemes in respect of the contribution of shares.
The appellant claimed income tax relief at source in respect of a net contribution of £68,324 made by an individual (C) to a self-invested pension plan (SIPP). HM Revenue and Customs (HMRC) refused the claim (the same facts and circumstances applied to three other individuals). The appellant appealed.
The issue was whether the contributions made by the four members of the SIPP were ‘paid’ (within FA 2004, s 188(1)) and, therefore, qualified for the tax relief.
On 9 March 2016, C had executed a SIPP contribution form, indicating that he proposed to make a net contribution of £68,324. On 24 March 2016, C wrote to the appellant confirming that this contribution would be made by way of an in specie transfer of shares. On 29 March,
