The couch tax shop?

The appellant appealed against HMRC’s amendment to her self-assessment return for the tax year 2002/03. The sum in question related to the costs that she had incurred principally on training or counselling sessions for her business.

HMRC said her expenses were not incurred wholly and exclusively for the purpose of her business.

Originating from a family in which wealth was passed on to male heirs the taxpayer created her beauty salon in 2002 initially to have something to call her own.

As the business grew the tribunal heard she had at one time up to seven employees. The costs for counselling arose as a consequence to her low self-esteem when dealing with staff; therefore over the year 2002/03 she attended and paid for 45 sessions in total.

She accepted that she had derived personal benefits from the sessions as they had given her more...