Irrelevant argument

The taxpayer used his UK home to carry on business as a consultant quantity surveyor providing some services through two companies that he used as umbrellas for other surveyors to work through.

He claimed expenses against the profits of the companies in his 2005/06 tax return. HMRC disallowed them on the ground he had not offered evidence to substantiate his claim.

The taxpayer appealed saying it was difficult to provide supporting documents because he had been abroad and his house was being renovated.

He added that the payments had been declared and taxed in the companies’ accounts and so should be deductible for him.

The First-tier Tribunal said the taxpayer had to show the expenses were wholly and exclusively incurred for the purpose of his trade. He had failed to do so.

It was irrelevant and entirely separate that amounts had been subject to corporation tax in the...