TC09561 - [2025] UKFTT 00761 (TC)
First-tier Tribunal (Tax Chamber)

TC09561 - [2025] UKFTT 00761 (TC)

Fecha: 03-Jun-2025

Length of the delay

Length of the delay

16.

We first considered the length of the delay. The earliest potential request for a review for which we had clear evidence was made on 30 July 2023, which is 134 days after 17 March 2023. Accordingly, the request for review was made 89 days after the expiry of the 45 day period specified in s14(2).

17.

We were invited by DBF to consider that the 30 July 2023 email was not a request for a review for the purposes of s14(2) and therefore the letter dated 28 March 2024 was the request for a review. It was made more than 330 days after the expiry of the 45 day period.

18.

A delay of 89 days in the context of a 45 day appeal period is clearly serious and significant; if the period is over 330 days the delay is even more serious and significant.