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Banker Grounded by £675,000 Tax Bill

Published by Prerana
Posted Date: June 26, 2024 , Modified Date: June 26, 2024

During a recent legal battle, an investment banker was required to pay a tax bill of £675,000. This was because his attempt to use business investment relief was blocked by HMRC. The case shows how complicated tax rules can be and how high-net-worth individuals can face difficulties when dealing with international finance.

How Did Personal Expenses Lead to a Tax Bill?

The European banker was a resident of the UK but not domiciled there in 2016. This status allowed him to benefit from special tax rules. He put £1.5 million of his foreign income into his newly established UK company, hoping that it would qualify for business investment relief and thus exempt him from UK taxes on the invested amount. However, the banker used £75,000 for personal expenses, such as private jets, a 79p iTunes subscription, and gifts for his wife, by setting up a director's loan account.

business investment relief

HMRC considered this as taking money out of the company without permission, which goes against the rules in the Income Tax Act 2007. As a result, HMRC refused to allow the business investment relief for the full £1.5 million, leading to a tax bill of £675,000.

Legal Arguments and Tribunal’s Decision

During the case, the representative argued that the director's loan did not breach the extraction of value rule, as it was a common practice in the industry and did not lead to a net extraction of value from the company. He stated that the personal expenses covered by the loan were typical for the industry.

However, HMRC argued that even a single personal expense violated the rule, making the entire amount taxable. The judge sided with HMRC, emphasising that the rule aims to strictly limit the circumstances under which value can be extracted without losing the relief. The judge concluded that any personal use of the company's funds breaks the relief conditions.


The decision to reject the banker’s appeal shows how strict tax rules are for business investment relief. Even though legal advisers offered guidance, the court determined that the rules were clear, and the relief was lost because company assets were used for personal purposes.

This case emphasises how important it is to understand and follow tax laws to avoid serious financial consequences. Investors need to be careful and make sure they comply with all the rules to protect their investments and tax position.

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