[2025] UKUT 00367 (TCC)

The Applicant (Convergence Management Consultants Ltd or “CMC”) applies to the Upper Tribunal (Tax and Chancery) (“UT”) for permission to appeal the decision of the First-tier Tribunal (Tax Chamber) (“the FTT”), released on 9 January 2025 (“the Decision”). The Decision was made by the FTT following a hearing conducted on 12 December 2024.

The FTT dismissed the Applicant’s appeal against HMRC’s decisions that CMC had to repay Coronavirus Job Retention Scheme (“CJRS”). HMRC made four assessments that the Applicant should repay a total of £46,619.48 representing amounts paid to the Applicant in respect of various claims made between April 2020 and September 2021.

By a decision dated 3 April 2025 (“the PTA Decision”), the FTT refused the Applicant permission to appeal the FTT’s Decision to the Upper Tribunal (‘UT’) on the grounds of appeal pursued. The Applicant renewed its application to the UT for permission to appeal in-time on 28 April 2025 within a month thereafter.

I refused permission to appeal to the UT on the papers on 23 June 2025. The Applicant renewed its application which was reconsidered at a video hearing on 27 October 2025. The Applicant was represented by its director and representative, Mr Mahmood. He relied on a bundle of documents and skeleton argument dated 7 October 2025 which he supplemented with oral submissions. HMRC were represented by Officers McCabe and Ramsay, the former who made brief oral submissions in reply. I am grateful to all parties for their assistance.