TC09512 - [2025] UKFTT 00522 (TC)

As we have found that commission income was received in February 2010, we conclude that HMRC were entitled to assess for commission income received in the tax year to 5 April 2010 at least in respect of the 78 students recruited at that time.

HMRC’s assessment estimated the income received at £30,000 for each of SA and NN. As indicated in the hearing we consider that assessment to be overstated. By comparison to the numbers of students recruited in subsequent years and the income declared for the recruitment services we consider that an estimate of £10,000 for each of SA and NN to be more appropriate for that year. It reflects that 78 students represented approximately 25% of the total students recruited in later years. One quarter of the income received in those later years is approximately £10,000.