The appellant, Mark Northwood, appealed to the FTT against closure notices issued by HMRC on 1 December 2016 amending his income tax returns, for the tax years ending 5 April between 2010-2013.

The amendments resulted in additional income tax and national insurance contributions (NICs) totalling £999,755.81.

Northwood argued that making contributions to a remuneration trust had the effect of reducing the taxable profits from his self-employed dentistry business and as a result his liability for income tax and NICs.

However, HMRC disagreed and amended Northwood’s tax returns to remove the deduction. Northwood appealed to the FTT against HMRC’s amendments.

Northwood qualified as a dental surgeon in 1988 and has conducted his orthodontist practice for some years as a sole trader. In 2009, he entered into discussions with Foy Wealth Ltd and law firm Baxendale Walker about setting up a remuneration trust.