2886.In Pardoe v Entergy Power Development Corporation (2000), 72 TC 617 ChD(13), the High Court held that a direction under section 777(9) of ICTA could be given if, and only if, at the time of the direction, HMRC were satisfied that there was a present entitlement to a relevant payment; a direction could not be given where there was only a prospect (however imminent) of future entitlement.
[2000] STC 286.
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