Mrs E Haseldine v HMRC

In Mrs E Haseldine v HMRC (TC02157 – 9 August) a woman (E) had been born in Switzerland in 1944. She lived and worked in Switzerland until 1967 when she moved to France. In 1968 she married a British diplomat. She subsequently acquired dual nationality and became resident in the UK. Between 1995 and 2009 she made voluntary contributions to her Swiss personal ‘old age and survivors insurance’ pension. She claimed relief for these contributions against her UK income. HMRC rejected the claim and she appealed. The First-tier Tribunal dismissed her appeal holding that the contributions failed to qualify for relief. Judge Walters observed that ‘voluntary national insurance contributions do not attract tax relief in the UK’. He also held that the effect of ITEPA 2003 s 575(2) was that only 90% of E’s income from her...