Loyalty bonus payments paid by platform service provider were not annual payments (Hargreaves Lansdown v HMRC)

Table of contents

• What are the practical implications of this case?
• What was the background?
• What did the court decide?
• Payable under a legal obligation
• Recurrent or capable of recurring
• Pure income profit
• Case details

Article summary

Tax analysis: The First-tier Tax Tribunal (FTT) found that certain loyalty bonus payments paid by a platform service provider to investors were not annual payments giving rise to an obligation to withhold income tax as they did not comprise pure income profit.