S Rowe

I and my accountant have reviewed every page of your guidance and it does not help. Please answer the following: 1) this is an investment company, not a trading company. Is it correct that CTA09/S1219 therefore applies? 2) in 1219, there is no "wholly and exclusively" test and L G Berry Investments Ltd v Attwooll 41TC547 turns on whether directors fees were reasonable, "having regard to the requirements of the company’s business and, in the case of directors’ fees or other payments for services, to the actual services rendered to the company" Since the wholly and exclusively test doesn't apply, the commissioners in Berry v Attwooll allowed about 1/3 of the profit as management fees. Having consulted https://www.gov.uk/hmrc-internal-manuals/company-taxation-manual/ctm08170 and https://www.gov.uk/hmrc-internal-manuals/company-taxation-manual/ctm08330, is the figure of about 1/3 of the profit in an investment company an allowable amount for the director to be paid for management services if they spend a few hours per week reviewing the investments, and not other activities for the company? 4) can the payment for management services therefore be made by way of a pension contribution, if no salary or dividends are paid to that director?

Hello HMRC, I have further questions on this please, which are not covered in CTM08340, which your referral to PTM043100 leads to. -I am sole shareholder and director of a limited investment company which makes £100-£300k per year profit from interest income -if I take no salary from that company, would a payment of £60,000 by that company into my personal SIPP be an allowable expense for corporation tax purposes? -if the company pays £180,000 into the SIPP for this year's pension limit and the 3 prior years', is that also an allowable business expense? There is no guidance on HMRC's website about making employer's payments to SIPP from investment companies, if no salary is taken. Thank you.

Hello. If my employer pays 3 x £60,000= £180,000 into my SIPP this tax year (this year's allowance, plus unused allowance from 2 prior years), should my Adjusted Income for this tax year show £60,000 or £180,000 from my pension? Thank you.

Hello, I am considering taking 25% cash tax free from my SIPP and continuing to contribute via my employer afterwards, and the advice on the internet is inconsistent. Grateful for your help please: 1. Does taking the 25% cash lump sum put my pension into draw down? 2 After I withdraw the cash lump sum, will my SIPP be able to accept contributions from my employer, which is my limited company? 3. Can the company pay in the £60k annual contribution, if the company pays me no salary? 4. Can the company use the previous 2 years' of unused reliefs too, taking this to £180k? 5. Does the timing matter - whether my employer contributes £60k and then I take the cash lump sum, or if I take the cash lump sum before the employer contribution? Thank you.