TC09629 - [2025] UKFTT 01070 (TC)

The only issue in dispute between the parties is HMRC’s assessment of the qualifying amounts claimed being excessive from 01 November 2020 to 21 March 2021.  

HMRC contend that amount of salary (reference payment) used when calculating a CJRS claim should be the employee’s salary for the period ending on or before 19 March 2020. This would amount to £719.00 for each director in this case.  

Smart contends that the reference payment should be the salary of the employee at the time of the claims being made, this being £3,250.00 per director.  

An analysis of the Coronavirus Directions is therefore required.