Howard Sharkett and Deborah Atkinson consider that there is a hardening in the Tribunal's approach to out of time appeals.
BackgroundThe 30-day time limit within which VAT appeals must be lodged with the First-tier Tribunal is contained in VATA 1994 s 83G. Broadly speaking (and putting aside the review provisions and HMRC’s power under the pre-2009 Tribunal Rules to extend the time for an appeal by 21 days) the time limit and the Tribunal’s power to extend it have been common features of the appeal regime.
In the absence of any statutory guidance the Tribunal’s approach to the...
