TC09670 - [2025] UKFTT 01260 (TC)

The Tribunal raised two issues of its own volition on which it sought the assistance of the parties. The Tribunal is grateful for their submissions. As we have been able to determine the application without reliance on those issues, what we say about them below is obiter dicta. However, we set out briefly our views.

The first issue is whether this appeal is in fact late at all. That turns on the interpretation of r.20 of The Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (“the FTT Rules”).

In interpreting any rule of the FTT Rules, the Tribunal must seek to give effect to the overriding objective (r.2(3)(b)). The overriding objective of the FTT Rules is to enable the Tribunal to deal with cases fairly and justly.

Under r.2(2) of the FTT Rules: