The basic redress and interest elements of a compensation payment by a bank to the taxpayer in respect of a mis-sold interest rate swap product were both taxable revenue receipts.

Summary 

The basic redress and interest elements of a compensation payment by a bank to the taxpayer in respect of a mis-sold interest rate swap product were both taxable revenue receipts. 

Background 

The appellant carried on a UK property rental business. In August 2005, he borrowed £840,000 from Barclays to refinance his existing borrowing from The Royal Bank of Scotland and to fund the acquisition of a property (the 2005 loan). Subsequently, the appellant borrowed £980,000 from Barclays to fund the acquisition of another property (the 2007 loan). The 2005 and 2007 loans carried