TC09550 - [2025] UKFTT 00702 (TC)

We have a great deal of sympathy for Mr Lucas who was misled by Apostle into authorizing claims which he believed to be legitimate, but which Apostle knew were not. However, we must apply the law as it stands.

We have found that HMRC made a valid discovery of an insufficiency of tax. The extended time limits for assessment apply because Apostle, which was acting on behalf of Mr Lucas, deliberately brought about the loss of tax. Accordingly, all the discovery assessments are valid.

We dismiss the appeal.

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.