TC09624 - [2025] UKFTT 01065 (TC)

Case Number: TC09624

[Taylor House]

Appeal reference: TC/2020/04151

INCOME TAX –payments received from sponsorship agreements reported through Appellant’s company – assignment of intellectual property rights between the Appellant and his company– the absence of the concept of “Image Rights” under English law –whether sponsorship agreements were made with the Appellant or with the company – the identity of the parties to the contractual agreements –objective test –the parol evidence rule – adverse inferences from failure to call witnesses – resort to the burden of proof – whether the Appellant is liable to income tax from income received as a result of the sponsorship agreements pursuant to s 8 and 5 or 687 of the Income Tax (Trading and Other Income) Act 2005 – yes – legitimate expectation – whether the Tribunal has jurisdiction to consider public law arguments in the context of an appeal under s 50 of the Taxes Management Act 1970 –no – Appeal dismissed

Judgment date: 28 August 2025

Before

JUDGE NATSAI MANYARARA

JANE SHILLAKER

Between

PAUL COLLINGWOOD

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Mr Stuart Rosenberg, Accountant

For the Respondents: Mr Joshua Carey of Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs

DECISION