TC09642 - [2025] UKFTT 01116 (TC)

Fecha: 30-Abr-2025

Introduction

Introduction

With the consent of the parties, the form of the hearing was V (video). A face to face hearing was not held because a remote hearing was appropriate.

The documents to which we were referred are:

(1)

A hearing bundle of 784 pages;

(2)

Skeleton arguments from HMRC (30 pages) and the Appellant’s response thereto (4 pages); and

(3)

Written submissions pursuant to written directions after the hearing from both HMRC (4 pages and an appendix of 13 pages of calculations) and the Appellant (3 pages).

Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings. As such, the hearing was held in public.

This was an appeal against four income tax assessments raised against Complete Solutions Europe Limited (CSEL) in relation to claims under the coronavirus job retention scheme (CJRS).