UT/2024/000093 - [2025] UKUT 00206 (TCC)

HMRC issued assessments to income tax to Mr Trachtenberg in relation to unauthorised payments made to him by his pension scheme. One assessment related to the tax year 2006/07, and the second to the tax year 2009/10. Mr Trachtenberg appealed against the assessments to the First-tier Tribunal (Tax Chamber) (the “FTT”). In a decision released on 9 May 2024 (the “Decision”), the FTT dismissed the appeal.

Mr Trachtenberg appeals against the Decision on a single ground. The ground is that the statutory provision relied on by HMRC to issue the assessments cannot be used to recover the amounts said by HMRC to be assessable.