The taxpayer was a small company owned by R who was the sole employee and director. During the pandemic R made several attempts to obtain government support but managed to do this only through the coronavirus job retention scheme (CJRS). He paid himself by a mix of salary – £400 a month – and dividends.
From June 2020 he increased his salary to £980 again in July to £1 400 in October to £2 240 and for November to September 2021 to £2 500. At the end of the CJRS his salary reverted to £400 a month. R explained the higher payments as necessary to support himself and the business but did not deny that it was also to increase his entitlement to CJRS payments.
The company made CJRS claims for periods from 1 March 2020 to 30 September 2021. These were based...
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