In Chepstow Plant International Ltd v HMRC (and related appeal) (TC01035 – 11 April) A company (C) purchased several racehorses.
HMRC formed the opinion that C had purchased the horses in order to confer a benefit on its principal director (H). They issued determinations on C charging Class 1A national insurance contributions and also issued income tax assessments on H. C and H appealed contending that C had purchased the racehorses for advertising purposes and that H had no personal interest in horse racing.
The First-tier Tribunal allowed the appeals observing that ‘there was no evidence that H had entertained customers of the company in person at any racing event or was present in any parade ring or had been observed in any situation with racehorses.’
Why it matters: HMRC seem to have assumed the...