Jonathan Wood v The Commissioners for HMRC
Decision date: 26 March 2026
Neutral citation: [2026] UKFTT 589 (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 appeal concerned nine payments totalling £747,500 by Mr Wood to unconnected political/campaigning bodies and whether those payments fell outside a transfer of value under s10(1) IHTA or were exempt as normal expenditure under s21 IHTA. The Tribunal found the payments were transfers of value because they objectively and subjectively conferred gratuitous benefits and rejected the s21 defence because the donations were not part of a settled pattern or prior commitment. The appeal was dismissed.
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: high
The Tribunal treated a transfer as conferring a gratuitous benefit where recipients were placed in a significantly better legal and practical position after receipt, and held that s10(1) IHTA is defeated if the donor intended to confer any gratuitous benefit; expectation of non‑enforceable influence does not negate that intention. For s21, "normal expenditure" requires a settled pattern established by prior commitment or a discernible recurring practice; ad‑hoc or need‑driven political donations without formula or commitment do not qualify.
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 observed that a donor’s hope of achieving broad political or financial outcomes (for example, Brexit) is generally too remote or contingent to amount to an intention under s10(1). It also noted that arguments about redundancy of other statutory provisions (such as s24) have limited weight but may inform interpretation where consistent with statutory wording and authority.