TC09554 - [2025] UKFTT 00747 (TC)

The Appellant’s case generally relied on the facts of the case speaking for themselves. However, within the Appellant’s letter of complaint to HMRC of 2 September 2024, the Appellant also asked:

“Is it not, therefore in HMRC’s interest to withhold our VAT for as long as possible to increase these penalties? I highlight the fact that there were no specific queries for ESC Studios from July 5th 2024 to August 13th. How is it fair for HMRC to profit from SME’s [a reference to small and medium-sized enterprises] penalties when there is no legitimate reason for withholding VAT repayment?”

The reference to “no legitimate reason” was predicated on the Appellant’s belief that, by then, HMRC were no longer asking reasonable questions