TC09523 - [2025] UKFTT 00544 (TC)

VP is seeking two separate, but related, reliefs from sanction.

The first is relief from the sanction imposed under Rule 8(6) Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009/273 (the “Tribunal Rules”). That rule provides that an application for sanction cannot be made later than 28 days after the order striking out the application. The second is to have the appeal reinstated under Rule 8(5) of the Tribunal Rules. The second relief from sanction can only be considered if the first relief from sanction is granted.  

It is respectfully submitted that VP has not demonstrated that there are good grounds for this Tribunal to extend the period for making the application for reinstatement. Accordingly, the Tribunal ought not to relieve VP of the failure to comply with the time limit in Rule 8(6) of the Tribunal Rules.

In the event that the Tribunal is satisfied that it is appropriate to extend time for making the application, it is respectfully submitted that the appeal ought not to be reinstated.

The relevant statutory provisions are Rules 2, 7 and 8 of the Tribunal Rules.