TC09527 - [2025] UKFTT 00563 (TC)

In the alternative, if this is a relief from sanctions case, the principles are set out in the case of William Martland v HMRC [2018] UKUT 178 (“Martland”).

In either case however, it is both in the interests of justice, and in accordance with the overriding objective in rule 2, to grant the application. There are good reasons for the need for the further extension. It was only once the appellant uploaded the relevant evidence onto the SDES system that HMRC were able to fully understand, and deal head-on with the appellant’s case. This needed to be reflected in the statement of case and instructions to draft this was sent to counsel on 29 January 2025. This was very shortly after the appellant’s documents had been received, the last of these being on 20 January 2025.

It is in the interests of the smooth running of this appeal that the statement of case dealt fully with all aspects of the appellant’s case, and that was not possible until HMRC had received all of the appellant’s evidence.

Counsel did not respond until 18 February 2025. The advice which accompanied the draft statement of case required further input from HMRC’s technical division. This too was required to finalise the statement of case.