Appeal dismissed. HMRC win. Get those titles stripped NOW.....
Conclusion
[92] For the foregoing reasons we will accordingly allow HMRC’s appeal on the first ground advanced by them. On that basis we will answer the fourth question in the appeal in the affirmative, and hold that the First-tier Tribunal erred in allowing the original appeal and that the Upper Tribunal erred in refusing the appeal before it. The other questions in the appeal do not therefore arise. The assessments to PAYE have been correctly made, for the reasons already discussed. On that basis we will recall the orders of the First-tier and Upper Tribunals and affirm the determinations appealed against, including that relating to PAYE, with the exception of the determinations and decisions concerning Sir David Murray in relation to the Bel Azur property transaction, which is conceded by HMRC. We will reserve the question of expenses in view of the history of the appeals.


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