TC09553 - [2025] UKFTT 00705 (TC)

The appeal filed to the Tribunal (“FTT”) by the Appellant is against an assessment raised by HMRC as a result of an error correction notice having been filed by the Appellant. The assessment was issued to the Appellant on 22 July 2023, for the periods 09/19, 11/19, 02/20, 03/20, 06/20 and 03/21. The only issue between the parties is whether that assessment was raised within the statutory time limits.

HMRC applied for this appeal to be struck out on the basis either that the FTT did not have jurisdiction or there was no reasonable prospect of the Appellant’s appeal succeeding. The FTT directed that both the strike out application and (if the strike out application was unsuccessful) the substantive appeal, be heard on the papers.

For the reasons set out below: