TC09552 - [2025] UKFTT 00704 (TC)

Case Number:TC09552

By remote video hearing

Appeal reference: TC/2023/07534

Coronavirus Job Retention Scheme – clawback of payments – payments made in respect of two employees whose employment had commenced before 19 March 2020, but where the first RTI return to include information about them post-dated 19 March 2020 – payments made to one employee where the first RTI return to include information about them post-dated 30 October 2020 – whether payments to those employees represented “qualifying costs” for the purposes of the Coronavirus Act 2020 and Functions of HMRC (Coronavirus Job Retention Scheme) Direction of 15 April 2020 as amended by subsequent Directions – no – whether appellant entitled to rely on public law arguments – no

Judgment date: 12 June 2025

Before

TRIBUNAL JUDGE ANNE SCOTT

MEMBER NASREEN HUSSAIN

Between

T HILLING & CO LTD t/a CHOBHAM ADVENTURE FARM

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Bean Chapman, Director of the Appellant

For the Respondents: Nathaniel Campbell, Litigator of HM Revenue and Customs' Solicitor's Office

DECISION