TC09523 - [2025] UKFTT 00544 (TC)

Fecha: 01-May-2025

Conclusions

Disposal

134.

The Applications being the Time Limit application and the Reinstatement application are refused.

Right to apply for permission to appeal

135.

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.

WILLIAM RUTHVEN GEMMELL

TRIBUNAL JUDGE

Release date: 16^th May 2025

APPENDICIES

Appendix A

Legislation – Tribunal Rules

Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009/273, Rule 2.

Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009/273, Rule 7.

Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009/273, Rule 8.

Appendix B

Authorities Referred To

Smith v Brough [2005] EWCA Civ 261.

Data Select Limited v the Commissioners for Her Majesty’s Revenue and Customs [2012] STC 2195.

Revenue and Customs Commissioners v McCarthy and Stone (Developments) Ltd [2014] UKUT 196 (TCC).

Romasave (Property Services) Ltd v Revenue and Customs Commissioners [2015] UKUT 254 (TCC).

BPP Holdings Ltd v Revenue and Customs Commissioners [2017] UKSC 55.

Martland v Revenue and Customs Commissioners [2018] UKUT 178 (TCC).

Revenue and Customs Commissioners v BMW Shipping Agents Limited [2021] UKUT 91 (TCC).