Payment was salary, not a bursary

Between April 2012 and March 2013 the taxpayer attended a course run by the University of Essex. In March 2017 he applied for a repayment of the income tax and National Insurance contributions deducted from his pay during the period he had attended the course.

He said the money he had been paid was a bursary and therefore exempt from tax under the ITTOIA 2005 s 776 and from NICs under National Insurance Contributions Regulations 2001 Sch 3 Pt VII para 12. In any event it was not taxable because the course had been part of a widening access training scheme (WATS) and so fell within the WATS ‘refunds for NHS trust workers concession’.

HMRC refused saying the claim was out of time.

The taxpayer appealed.

The First-tier Tribunal decided that the payments to the taxpayer were not a bursary and so did not fall within...