Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February) the taxpayer was given limited permission to appeal to the UT against closure notices assessments and penalties. The decision of the UT in rejecting the appeal is largely fact specific but paras 40 onwards are worth reading for their discussion of the consequences of an FTT not giving adequate reasons for its decision. Although in the end this failure had no effect on the outcome of the case the comments will be worth noting by those who wish to appeal in other cases where the reasons for a decision are not clearly articulated.
Failure by an agent as reasonable excuse: PBS Wholesale Ltd and others v HMRC [2025] UKFTT 210 (TC) (14 February) is a late appeal case. The details are unlikely to be of general interest but...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February) the taxpayer was given limited permission to appeal to the UT against closure notices assessments and penalties. The decision of the UT in rejecting the appeal is largely fact specific but paras 40 onwards are worth reading for their discussion of the consequences of an FTT not giving adequate reasons for its decision. Although in the end this failure had no effect on the outcome of the case the comments will be worth noting by those who wish to appeal in other cases where the reasons for a decision are not clearly articulated.
Failure by an agent as reasonable excuse: PBS Wholesale Ltd and others v HMRC [2025] UKFTT 210 (TC) (14 February) is a late appeal case. The details are unlikely to be of general interest but...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
