![TC09660 - [2025] UKFTT 01226 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png){kind=logo}
The Rangers decision was released after the tax year under consideration
The Rangers decision was released after the tax year under consideration.
HMRC have been guilty of inordinate delay. The first letter he received was in 2012, and it is incredible that in 2025 the matter is still being discussed. This delay was not something which was properly considered by HMRC and in particular by the reviewing officer.
Every time that he has dealt with HMRC, he has dealt with a different officer. His case has been handled inconsistently and there have been errors in documents that he has received.
- Heading
- INTRODUCTION
- THE EVIDENCE AND THE FACTS
- DISCUSSION
- There is no justification for HMRC saying that the tribunal has no jurisdiction in relation to his appeal
- The Rangers decision was released after the tax year under consideration
- The loan was repaid and thus there is no liability to tax on it
- The effect of the decision in RFC 2012 plc (formerly the Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45 (“ Rangers ”) is that the payments made by the employer to the trust
- The decision in Hoey v HMRC [2022] EWCA Civ 656 (“ Hoey ”) is authority for the proposition that this tribunal has no jurisdiction to consider HMRC’s discretion to impose any tax on Mr Brown rather th
- There is no justification in the complaints made about the statutory review process which was undertaken wholly properly The application of the loan charge legislation is not relevant to this appeal
- My view
- Conclusions