In Douglas Boulton v HMRC [2026] TC09846, the First Tier Tribunal (FTT) found that a director’s settlement agreement with the liquidator of his company resulted in his director’s loan account being released or written off, giving rise to an Income Tax charge.
Mr Boulton was the sole director and shareholder of Sameday Express UK Ltd (SEUK Ltd).
- SEUK Ltd’s 28 February 2013 accounts and Corporation Tax return recorded a Director’s Loan Account (DLA) balance of £151,802 owed by Mr Boulton.
- On 12 June 2014, SEUK Ltd entered Creditors’ voluntary liquidation. The Statement of Affairs, signed by Mr Boulton, showed that he owed only £18,000.
- The liquidator queried the inconsistency and continued to pursue the debt…