TC09510 - [2025] UKFTT 00501 (TC)

Because case law makes it plain that the relevant conduct is only that which happens after an appeal falls fully within the jurisdiction of the Tribunal, I consider that HMRC in the relevant time period have not acted unreasonably in ‘bringing, defending or conducting the proceedings’.

Accordingly I refuse the application for costs.

This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.