At the First Tier Tribunal (FTT) appellant Brian Lynch disputed three HMRC closure notices related to his involvement in the Caledonian tax avoidance scheme over a four-year period between 2010-11 and 2013-14.

In total, HMRC issued a dry tax demand for £9,937,913, including two years of high income child benefit charge (HICBC).

Lynch appealed on three grounds, the first being against the ‘dry tax’ income tax charges which were issued as a result of him using the Caledonian scheme and the second a challenge against the discovery assessment. The third issue at stake was an appeal against high income child benefit charge, which he claimed breached his human rights and interfered with the ‘enjoyment of his money’, despite owing almost £10m in tax.

Lynch