HM Revenue & Customs (HMRC) issued income tax assessments in relation to the appellants’ use of assets (i.e. yachts, jewellery and antique clocks) owned by two companies of which they were directors. The appellants (Mr and Mrs R) appealed.
One of the companies owned a succession of yachts, which were used (among other things) as a business base, and for charter. The jewellery was purchased by another company to be worn by Mrs R and her daughter to “convey the right image” at “need to impress” company occasions. The antique clocks were not kept at the appellants’ private residence, and the First-tier Tribunal (FTT) found that they were acquired for business purposes.
In view of the very wide definition of ‘benefit’ in ITEPA 2003, s 201, the FTT considered that a benefit-in-kind arose (under s 205) as a result of the yachts, jewellery and clocks being placed at the&
