Lee Sharpe looks at some key concepts of property taxation that are pivotal to HMRC enquiries.
The recent case Akhtar v HMRC [2025] UKFTT 00395 (TC) covers how ownership relates to the taxation of property income and gains, and ‘unexplained bank receipts’.
Background
Mr Akhtar had run a taxi company from 2006 through to around 2019 (including its successor).
In 2011, HMRC opened an enquiry into Mr Akhtar’s 2008/09 tax return, during which it transpired Mr Akhtar was registered as owning as many as six properties, but had not returned any rental income in the period 2008/09 to 2011/12. The first time Mr Akhtar included rental income in his tax return was for 2012/13 – a good while after the enquiry had commenced.
Furthermore:
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Each property was in his sole legal name (save the,
