TC09656 - [2025] UKFTT 01207 (TC)

For all the reasons above the application for permission to make a late appeal pursuant to section 83G(4)(c) is GRANTED.

LL Ltd shall provide to HMRC and the Tribunal no later than 28 days after the date of this decision its amended grounds of appeal detailing the reasons that it disagrees with the Decision Letter, taking account of the amendment made by paragraph 67 of HMRC’s Notice of Objection dated 14 March 2025, and the subsequent payment made by HMRC on 8 September 2025.

HMRC shall provide their Statement of Case to LL Ltd and the Tribunal no later than 28 days after LL Ltd’s compliance with the direction at paragraph 81 above.

This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.