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PI Murtagh v HMRC

Management of golfers: whether trading

In PI Murtagh v HMRC (TC02754 – 27 June) a pharmacist (M) had two sons who were both professional golfers. He submitted tax returns claiming loss relief on the basis that he was carrying on a trade of managing professional golfers. HMRC rejected the claim and the First-tier Tribunal dismissed M’s appeal finding that his activities were aimed at fostering his sons’ careers and did not constitute ‘a trading venture’.

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Why it matters: The First-tier Tribunal upheld HMRC’s view that the activities which the appellant was undertaking to promote his sons’ careers as golfers did not amount to a trade so that he could not gain tax relief for his expenditure by setting it against his other income.

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