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M Hepburn (TC2837)
The taxpayer formed Envireneer Ltd in April 2004. She was appointed in October 2005 to provide consultancy services to the business but she was required to do so through a separate company. She set up Torglenn.
Envireneer made a payment in respect of the consultancy fee to its solicitors to hold in a client account for Torglenn. The payment was transferred to Torglenn after the company was incorporated.
Torglenn included in its accounts and corporation tax return the fee as income – but HMRC concluded after an enquiry that the payment should be treated as made to the taxpayer and taxed as self-employed income.
The taxpayer appealed.
The First-tier Tribunal found there was never an intention for the consultancy fee to be paid direct to the taxpayer. She had to incorporate a company to provide the consultancy services and the payment was made to the business.
“No...
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