[2025] UKUT 166 (AAC)

First and foremost, HMRC says that the Tribunal’s factual findings dispose of this part of the appeal.

The Tribunal found that the claimant had made a valid declaration of eligibility for an entitlement period in respect of TFC. Indeed, that is apparent from the fact that HMRC was issued with an electronic notice sent for the purposes of informing it of such a declaration. The Tribunal stated that in making that application the claimant “…would have had to take positive action by completing the various fields and confirming, for example, that he and his wife were working and that they met the requirements for earnings”. If he had not made a declaration confirming his eligibility, HMRC would not have considered (and granted) his application to open a childcare account.

The Tribunal was right to make the findings of fact which it did regarding the application process and, unsurprisingly, the claimant does not challenge them (nor could he).

In any event, any doubt about the correctness of the Tribunal’s findings can be settled by reference to the “gov.uk” archived website at