Northwood v HMRC – FtT dismisses “remuneration trust” appeal

” The First-tier Tribunal has dismissed an appeal against closure notices issued by HMRC which disallowed deductions claimed in relation to contributions to a “remuneration trust”.

The FtT found that:

• The payments to the remuneration trust did not give rise to an expense under GAAP;
• The payments were for the taxpayer’s personal benefit and were not wholly and exclusively for the purposes of his trade;
• The related professional fees were not wholly and exclusively for the purpose of his trade; and
• The documentation relating to the remuneration trust was a sham.

Hui Ling McCarthy KC acted for HMRC and the decision can be found here: Northwood v HMRC [2023] UKFTT ”.