TC09642 - [2025] UKFTT 01116 (TC)

HMRC acknowledge that they made the errors made in issuing, cancelling and amending assessments and apologises for the confusion caused.

However, HMRC submit that the Tribunal does not have jurisdiction over HMRC’s conduct and that therefore the appropriate action regarding complaints is to use HMRC’s complaints process, followed, if necessary, by a complaint to the ombudsman.

With regard to the question of whether HMRC misled CSEL when it allowed further claims to be submitted, HMRC submit that this was not the case, as a matter of fact, but even if it was, this would be a claim based on public law arguments of legitimate expectation, which is not within the jurisdiction of this Tribunal.