The appellant, Mrs A, had made a claim for repayment related to income tax deduced on a payment of £1,055,000 paid to her under a settlement agreement between herself and her employer.

In the settlement agreement, the appellant was awarded £1,055,000 and an additional £45,000 in compensation fees, after agreeing to withdraw claims against her employer regarding accusations of sexual assault and harassment.

The appellant had also agreed to certain confidentiality and non-disclosure obligations, which she believed made her compensation fee exempt from tax charges.