TC09548 - [2025] UKFTT 00700 (TC)

HMRC also applied at the end of the PTA Application for the case to be stayed “pending determination of this appeal”. There was a delay of 19 days before the PTA Application was passed to me by the Tribunal Service, and further time passed before I was able to consider and decide that Application. I thus extend HMRC’s compliance date for the Directions to 35 days from the date of issue of this PTA Decision.

I considered whether to stay the appeal further, pending any future onward PTA application to the UT, but decided that it would not be in the interests of justice to do so. As explained above, there have already been significant delays in this case, and waiting for the UT to determine a PTA application relating to these two case management decisions may take many months, given the workload of that Tribunal. In addition, it was no part of the PTA Application that any of the Directions would not assist the parties and the Tribunal to move the case towards a hearing.

If HMRC are dissatisfied with the outcome of their PTA Application, they have a right to apply to the Upper Tribunal for permission to appeal.

Such an application must be made in writing to the Upper Tribunal at 5th Floor, Rolls Building, 7 Rolls Building, Fetter Lane, London EC4A 1NL no later than one month after the date of this Notice and must include the information explained in the enclosed guidance booklet Appealing to the Upper Tribunal (Tax and Chancery Chamber).