- A good example of an orthodox application of the earn-out provisions (Briggs and others v Revenue and Customs Commissioners)
- What was the background to the case?
- What did the tribunal decide?
- What are the practical implications of the case?
Private Client analysis: The First-tier tribunal (FTT) has sided with HMRC in its decision that a deed of variation and subsequent cash payments of the pass through payment (PTP) amounted to a disposal of the earn-out rights acquired under the Sale Purchase Agreement. John Brinsmead-Stockham, barrister at 11 New Square Chambers, explains why the ruling is a good example of an orthodox application of the earn-out provisions.
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