TC09633 - [2025] UKFTT 01096 (TC)

HMRC bears the burden of proving the Appellant did not satisfy the conditions of the Coronavirus Direction and is liable to an income tax charge under paragraph 8 FA 2020, as assessed under paragraph 9.

The burden is on the Appellant to prove it has been overcharged by the assessment.

The standard of proof is the ordinary civil standard, on the balance of probabilities.