TC09637 - [2025] UKFTT 01100 (TC)

Case Number: TC09637

GEORGE HOUSE, EDINBURGH

Appeal reference: TC/2023/09387

CORONAVIRUS JOB RETENTION SCHEME - Clawback of payments - amended assessment made after Alternative Dispute Resolution process - whether the assessment was made in accordance with the Coronavirus Act 2020 and Functions of HMRC (Coronavirus Job Retention Scheme) Direction of 15 April 2020, as amended by subsequent Directions – yes - whether under claimed amounts of payments could be offset against over claimed amounts identified in the assessment process - no - whether the appellant was entitled to rely on public law arguments in relation to fairness – no - Appeal dismissed.

Judgment date: 11 September 2025

Before

TRIBUNAL JUDGE RUTHVEN GEMMELL WS

CHARLOTTE BARBOUR CA CTA

Between

CITY BLINDS SCOTLAND LIMITED

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Tom Dyer, of Ascot Tax Accountants (“counsel for the Appellant”)

For the Respondents: Vikki Anne Wood, litigator of HM Revenue and Customs’ Solicitor’s Office (“counsel for the Respondents”)

DECISION