TC09602 - [2025] UKFTT 00930 (TC)

If permission were to be given, HMRC would have to divert resource to prepare for the appeal and attend the hearing. Those are resources which could be used to ensure that other taxpayers were paying the correct amount of tax.

One of the factors on which the Tribunal must place particular weight is that litigation is to be conducted efficiently and at proportionate cost, see Martland at [44] cited above. The PLN relates to periods 01/15 to 06/19, already between ten and six years ago, so it is likely to be more time-consuming and difficult for HMRC to collate and review all the relevant evidence. However, the PLN itself was issued on 26 August 2022 and the Notice of Appeal was filed on 2 December 2022. The time and effort required by HMRC and the Tribunal Service will only be slightly greater than had there been compliance with the directions, so the weight to be ascribed to this factor is in consequence lower.