Mohammed Maasher v The Commissioners for HMRC
Decision date: 18 June 2026
Neutral citation: [2026] UKFTT 911 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This is an appeal by Mr Maasher against an HMRC Closure Notice for 2020–21 disputing increased turnover and reduced expenses. The Tribunal held the Closure Notice complied with statutory requirements but allowed the appeal in part, accepting many of Mr Maasher’s expense claims (including subcontractor payments to his wife and daughter, travel/subsistence, a one‑third use‑of‑home apportionment, and certain property repairs) while disallowing charity donations and a medical payment. The Tribunal found HMRC’s case inconsistent in places and directed the parties to confirm quantum and penalty issues within 28 days.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
Where a taxpayer adduces contemporaneous documentary communications (such as emails showing assignments and returns of work) together with declarations from the recipients, those materials can support subcontractor expense claims even in the absence of formal payslips or timesheets; additionally, an officer issuing a closure notice (or relying on its conclusions) should be able to account for material recalculations relied on in later correspondence, and unexplained recalculations by other HMRC officers weaken HMRC’s position.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal noted procedural shortcomings by HMRC — including failing to notify the taxpayer that submitted email attachments were inaccessible and giving incorrect advice about CIS treatment — and observed that HMRC’s acceptance of some items (e.g. accommodation) without explaining inconsistent disallowance of related costs (e.g. travel) undermines fairness; these observations were made as commentary rather than decisive holdings.