TC09671 - [2025] UKFTT 01261 (TC)

Fecha: 15-Oct-2025

Introduction

Introduction

This is our decision on an application (the “Application”) by the Appellant, Mr Najat Hamasala, for the Tribunal’s permission to:

(1)

admit (and determine) a late appeal against a closure notice amending his 2014-15 self-assessment tax return and ‘discovery’ assessments for 2012-13, 2013-14 and 2015-16 issued by HM Revenue and Customs (“HMRC”) under s 29 Taxes Management Act 1970 (“TMA”) on 5 June 2017; and

(2)

give notice of his appeals to HMRC against late filing penalties totalling £3,955 for 2013-14 to 2016-17 inclusive (as set out in the schedule in the Appendix, below) after the expiry of the “relevant time limit”.

The Respondents, HMRC oppose the Application.

At the conclusion of the hearing at Cardiff Civil and Family Justice Centre on 15 October 2025, and after a short adjournment, we gave an oral decision dismissing the Application following which Mr Hamasala indicated he wished to consider an appeal.

Rule 35(4) of the Tribunal Procedure (First-tier Tribunal)(Tax Chamber) Rules 2009 provides that a party wishing to appeal must apply for full written findings and reasons for the decision before seeking permission to do so. We have therefore provided this decision in order to enable Hamsala to decide whether to apply for permission to appeal and to assist him in formulating any such appeal.