TC09517 - [2025] UKFTT 00527 (TC)

This decision deals with an application (“the application”) by the appellant for permission to bring an appeal against HMRC’s decision contained in two closure notices for the tax years 2011/2012 and 2012/2013, which were issued on 9 August 2017 (“the closurenotices”). The closure notices increase the amount of tax due for the 2011/2012 tax year by £13,388.77, and for the 2012/2013 tax year, by £13,267.77.

The appellant appealed to HMRC against the closure notices on 22 September 2017, which although late, was accepted as a valid appeal by HMRC.

However, the appeal was not notified to the tribunal until 26 February 2024. This was, in HMRC’s view, over four years and nine months late. In her notification to the tribunal, the appellant sought permission to bring the appeal out of time. HMRC oppose the application.

For the reasons given later in this decision, I reject the application and refuse permission for the appellant to bring her appeal out of time.