Upper Tribunal Tax and Chancery Chamber

[2025] UKUT 00377 (TCC)

Fecha: 16-Ene-2025

JUDGE RUPERT JONES Introduction

JUDGE RUPERT JONES

Introduction

The Applicant (Haron Mayet or “Mr Mayet”) 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 16 January 2025 (“the Decision”). The Decision was made by the FTT following consideration of his appeal on the papers between 2 and 10 January 2025.

The FTT dismissed the Applicant’s appeal against the following decisions of HMRC made in relation to him:

Discovery assessments made pursuant to section 29 Taxes Management Act 1970 (TMA) for each tax year ended 5 April 2000 to 5 April 2014 and tax year ended 5 April 2016 as varied on review (totalling around £240,000);

Penalties issued pursuant to schedule 18 Finance Act (No 2) 2017 for tax years ended 5 April 2000 to 2014 inclusive (Sch 18 Penalties); and

Penalties issued pursuant to schedule 24 Finance Act 2007 for tax years ended 5 April 2014 to 2016 inclusive (Sch 24 Penalties)

(Together the Sch 18 Penalties and Sch 24 Penalties were referred to as Penalties by the FTT. They totalled around £410,000).

The Assessments and Penalties were issued by HMRC because they considered that the Applicant had deliberately (as regards the Assessments and Sch 24 Penalties) failed to declare and bring into account (1) income from his trade providing property management services to customers and (2) interest income from Isle of Man (IoM) bank accounts.

References in square brackets [] are to paragraphs in the Decision unless context requires a different interpretation.

By a decision dated 27 March 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 his application to the UT for permission to appeal in-time on 22 April 2025 within a month thereafter.

On 24 June 2025 I refused permission to appeal to the UT in respect of all the grounds of appeal then pursued by the Applicant (who at that time was unrepresented).

The Applicant requested reconsideration of his application for permission at an oral hearing which took place before the UT by video on 30 October 2025. I note that the Applicant attended the video hearing before the UT in person by videolink from South Africa. Ms Siobhan Duncan of counsel appeared for the Applicant, making oral submissions and relying upon Revised grounds of appeal dated 24 October 2025. She filed post hearing supplementary submissions on 31 October 2025.

Mr Max Simpson of HMRC appeared for the Respondents at the hearing relying on oral submissions and a written response dated 27 October 2025. During the hearing on 30 October 2025, the parties also forwarded to the UT copies of emails sent to the FTT by the Applicant on 16 and 29 December 2024 and letters sent by the FTT to the Applicant on 12 and 17 December 2024.

I have considered all written and oral submissions.