TC09606 - [2025] UKFTT 00958 (TC)

The following facts were not in dispute.

DP Langan Limited (DPL) is a company providing electrical services through its director, Dermot Langan.

DPL also employed an administrator, whom we will refer to as Ms G.

In the periods prior to March 2020, Mr Langan had been paid £100 per week, and Ms G had been paid £191.23 per week.

On 11 April 2020, DPL increased their salaries, such that Mr Langan was now earning £576.93 per week, and Ms G was now earning £239.04 per week.

DPL made 15 claims under CJRS through its agent, John Tann & Co Accountants, for the period covering March 2020 to June 2021. These claims were made based on the higher salaries.

The first claim was submitted on 20 April 2020 and covered the period from 1 March 2020 to 18 April 2020. The remaining claims were made once a month and covered, approximately, a month each.

On 20 September 2022, HMRC opened a compliance check into DPL’s CJRS claims and enclosed a list of questions.

After a series of further information requests and correspondence, HMRC raised income tax assessments on 28 August 2023. The amounts assessed were:

On 15 September 2023, DPL appealed to HMRC and requested an internal review.

On 27 September 2023, HMRC issued their view of the matter letter.

On 5 January 2024, HMRC issued their review conclusion letter, which revised the first assessment, for the year ending 5 April 2021, upwards to £21,054.22. This was due to an incorrect percentage having been used for one of the months in the original assessment. The total due after such amendment was £26,418.26.

On 2 February 2024, DPL made an appeal to this Tribunal.