This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our privacy notice.

Information about consultancy fees was reasonably required by HMRC to check the consultant’s tax position

By Mark McLaughlin, July 2023

HMRC met the burden of proving that items requested in an information notice were “reasonably required for the purpose of checking the taxpayer’s tax position” in connection with consultancy fees paid into the appellant’s bank accounts, which did not seem to have been included as the turnover of a related company. 

The appellant, a clinical consultant, had worked for NHS Trust hospitals in London and was on the teaching staff of Imperial College, London, while also running a private practice, for which clinical consultancy fees were received. The appellant retired from the NHS in 2020. He continued with Imperial College and his private practice. The appellant was the only director and the majority shareholder of a company (GRI).  

In July 2019, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s self-assessment return for the tax year 2017/18. On 25 September 2019, HMRC requested details of

Subscribe to the McLaughlin’s Tax Case Library to get instant access
to the Tax Case Library.
14 day free trial , 90 day money back guarantee
Subscribe

Related or similar articles

Compensation received due to mis-selling of interest rate hedging products was taxable income
By Mark McLaughlin, March 2026
Compensation received due to mis-selling of interest rate hedging products was taxable income
By Mark McLaughlin, November 2024
Taxpayer entitled to costs for HMRC’s unreasonable conduct
By Mark McLaughlin, May 2023
LLPs entitled to EZAs based on apportionment to determine expenditure on the relevant interests in buildings
By Mark McLaughlin, April 2021
Misunderstanding about whether tax return was fully complete was a reasonable excuse
By Mark McLaughlin, January 2021