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Racy tale of lavish gifts ends with large tax bill

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Advisor claimed valuable gifts from Ecclestone business and family weren’t taxable, but his story finds no traction and crashes into the barrier of truth.

4th Jun 2021
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Stephen J Mullens’ (TC08112) attempted to persuade HMRC and the first-tier tribunal (FTT) that huge payments he received from racing impresario Bernie Ecclestone’s businesses, as well as  from Ecclestone’s ex-wife and trusts, inextricably involved in Ecclestone’s business dealings, were gifts which had nothing to do with business. He claimed these lavish “gifts” arose solely out of personal affection that had arisen over the course of a 25 year business relationship with the Ecclestone organisation.

Front of the grid

This case began with a false start when Mullens, who is a solicitor, failed to record on his tax returns a series of payments coming overall to just under £40 million according to the schedule HMRC provided to the FTT:

(1)          1999/2000            £1.2 or 1.25m (recorded but incorrectly)

(2)          2001/2002            £750,000

(3)          2006/2007            £300,000     

(4)          2006/2007            £21,846,200  ($38m)        

(5)          2008/2009            £10,015,005

(6)          2012/13                £5m             

(7)          2008/2009            £187,271 ('Holiday Payment')

Payments 1, 2 and 3 were made following Mullens’ involvement in a deal made by an Ecclestone company (Bambino Holdings Ltd. – BHL), allegedly to induce him to resign his position as the main partner in law firm Marriott Harrison to devote his time exclusively to the Ecclestone family interests.

Payments 4, 5 and 6 and the holiday payment were made by or at the instigation of Bernie Ecclestone’s ex-wife Slavica.

Mullens contended that he did not need to return any of the payments because none was taxable. The explanations put forward by Mullens’ barristers were many and various, and contained a level of swerves, baulking and obstruction that would have seen any racing driver disqualified in an instant.

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Replies (2)

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By Justin Bryant
04th Jun 2021 17:10

And what about VAT on these so-called gifts.? I suppose if they are VAT exclusive it could be worse for him than if they included VAT due to HMRC missing some VAT assessment deadline or whatever.

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By kestrepo
07th Jun 2021 15:40

I wonder if this was a simple case of banking some money with the hope of finding an excuse afterwards if needed. The numbers are so much bigger than normal they hide well in plain sight!

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