TC09592 - [2025] UKFTT 00891 (TC)

This decision concerns an application by the Respondents (HMRC) for a direction under Rule 8(3)(c) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (the “FTT Rules”) to strike out the appeal by the Appellant (OM Cash and Carry Ltd) on the grounds that the case has no reasonable prospect of success.

HMRC also applied for permission to amend their original strike-out application. The Appellant objected to this application. The Tribunal directed that the application to amend the original application would be considered together with the strike-out application itself.

For the reasons given below, I permit HMRC to amend their strike-out application, and grant the application for the appeal to be struck out.