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Victorangle Ltd (TC2994)
The director of the taxpayer company was a professional gambler who made his living from betting on horse races.
His bookmakers closed his accounts in 2004 claiming the move was because of his success. He began to place bets through third parties claiming all winnings.
The benefit to the third part was that he or she could place bets on horses backed by an experienced gambler.
HMRC said that the taxpayer company was supplying racing tips to clients. There was a direct link between the supply of information and payment for that information; the client placed a bet based on knowledge supplied by the director and accounted to him.
The taxpayer argued that the third party was supplying a service by placing bets and collecting and remitting the winnings.
The First-tier Tribunal said HMRC’s argument was “illogical”: there was no guarantee the backed horse would win when the...
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