Income tax – Pension. The taxpayer company's appeal against the imposition of certain charges on it following income tax assessments issued by the Revenue and Customs Commissioners, in respect of a loan made to the taxpayer from a pension fund, was dismissed by the First-tier Tribunal (Tax Chamber)(the FTT). The FTT held that in the circumstances, the payments comprising the loan did not satisfy the relevant statutory criteria set out in the Finance Act 2004 and the taxpayer had failed to establish that it would not be just and reasonable for it to be liable to those charges.