The First Tier Tribunal (FTT) ruled that the contributions to a remuneration trust by the company Strategic Branding Ltd were not deductible from profits for corporation tax but the amounts that were lent to the director were within the disguised remuneration rules.

The consulting company Strategic Branding Ltd (SBL) started making contributions to a marketed tax avoidance scheme in 2011 which was intended, in return for a fee of 10%, to give the company a corporation tax deduction and allow for the removal of tax and national insurance contributions (NICs) from the sole director and shareholder of the company.