TC09629 - [2025] UKFTT 01070 (TC)

The form of the hearing was V (video). We heard Mr Ian Hallam for the Appellant and Ms Lucy Lawrence, Litigator of HM Revenue and Customs’ Solicitor’s Office for the Respondents. The form of the hearing was V (video). The documents to which we were referred are 349-page documents bundle (which included relevant legislation, witness statements of Ian Hallam and Valerie Wescott and HMRC’s statement of case), HMRC’s Skeleton Argument. We were also referred to 2 decisions of the Tribunal.

Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings. As such, the hearing was held in public.

Smart H&L Ltd (‘Smart’) is appealing against HMRC’s assessment dated 11 January 2023 pursuant to Paragraph 9 Schedule to the Finance Act 2020 in the amount of £18,236.80. The relevant tax period is year ending 5 April 2021.  

HMRC contend that, following a review, the correct amount should be £18,335.60 and it seeks a finding to that effect.  

The assessment was issued based on payments received by Smart under the Coronavirus Job Retention Scheme (‘CJRS’) as introduced by the Coronavirus Act 2020. HMRC contend that Smart received payments under CJRS between the period of 1 November 2020 to 31 March 2021 which it was not entitled to.