TC09574 - [2025] UKFTT 00852 (TC)

This decision deals with HMRC’s application to strike out the appellant’s appeal on the basis that the tribunal has no jurisdiction.

The basis of this application is that the consequential amendments made to the appellant’s tax returns for three tax years following the closure of an enquiry into a film partnership of which the appellant was a member, are not appealable decisions within the ambit of section 31 Taxes Management Act 1970 (“TMA”).

Following the hearing I sought submissions on whether, amongst other things, the appellant’s appeal could be construed as an appeal under the provisions of section 32 TMA.

I am grateful to the appellant and to Mr Riaz for their oral and written submissions at the hearing and their subsequent written submissions thereafter. I have considered these in detail even though I have not found it necessary to refer to each and every one of them in reaching my conclusions.

For the reasons given later in this decision I have decided that HMRC are correct and the tribunal does not have jurisdiction in relation to these proceedings. I have therefore struck them out.