HMRC’s calculation of additional tax and National Insurance contributions liabilities and penalties were confirmed by the First-tier Tribunal in the absence of credible evidence by the appellant, including in respect of movements in his bank accounts.   

The appellant, a sole trader who provided project and business advisory services, was based in the UK, but his clients were based around the world, particularly in Nigeria and South Africa. The appellant had a network of contacts around the world that he could use to provide advice to his clients.

The appellant stated that he carried out errands for some of his clients on a "non-profit" basis to maintain goodwill with the client and enhance his business relationship with them. As the transactions were undertaken at no profit and done to preserve goodwill with the client, the appellant said the amounts