Former adviser to the Ecclestone family found liable to pay tax, interest and penalties of over £20m

Following a two-week hearing, the First-tier Tribunal (Tax Chamber) has decided that nearly £40 million received by Stephen Mullens, a solicitor and adviser for Bernie Ecclestone, Slavica Ecclestone and their family interests, was taxable as his income.

In respect of the vast majority of the monies, which were received from Mrs Ecclestone, the Tribunal rejected Mr Mullens’ case that he was “a person upon whom Mrs Ecclestone, like a rich elderly aunt, showered largesse by way of a series of spontaneous gifts in the order of tens of millions of pounds”. Rather, it found that the payments were a reward for Mr Mullens’ services in the restructuring of Formula One, and in respect of a tax investigation by HMRC and subsequent litigation involving Mr Ecclestone.

In addition, the Tribunal determined that the £2.25m received when Mr Mullens left his old firm to work for the Ecclestones was not a non-taxable inducement to leave but rather a taxable signing-on payment.

The Tribunal also dismissed Mr Mullens’ appeals against the penalty determinations in respect of the sums received from Mrs Ecclestone and the signing on payment.

Akash Nawbatt QC, Christopher Stone and Bayo Randle represented HMRC.

To read the full decision, please click here.

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