TC09682 - [2025] UKFTT 01334 (TC)

The substantive issues in this appeal concern transactions relating to a ‘Self-Employed Remuneration Trust’ where deductions were claimed in relation to trust costs and contributions into GC Wealth RT Ltd in the tax years 2017/18 to 2021/22.

The Appellant included in their tax returns deductions which were described as relating to contributions made to a “creditor protection trust” and asserted that the contributions were "allowable property expenses”. Some of these contributions related to rental income.

The Appellant’s appeal is against HMRC decisions resulting in additional tax of £76,733 and penalties in the amount of £37,599 for the same periods.