Payments were taxable income not gifts

For many years the taxpayer was engaged in the business affairs of Bernie Ecclestone the Ecclestone family and the Ecclestone family interests. Between 1999-2000 and 21012-13 he received several payments which totalled nearly £40m. Broadly the taxpayer said none of these were taxable but HMRC considered they were subject to tax as employment income.

The First-tier Tribunal considered each payment individually. On three large payments made to the taxpayer by an Ecclestone company the taxpayer said these were to induce him to resign his partnership in a law firm so to be able to offer his services to Formula 1. The tribunal disagreed. It said they were received as consideration for services rendered and therefore a receipt of a trade or profession.

The taxpayer said that three further large payments were gifts made to him by or at the direction of Mrs...