UT/2024/000093 - [2025] UKUT 00206 (TCC)

The single ground of appeal renews the two alternative arguments rejected by the FTT, namely that (1) section 29 TMA 1970 cannot be used to assess the charges otherwise than under regulations made under section 255 FA 2004, and (2) section 29 does not cover the charges as they are not tied to any year of assessment and cannot be self-assessed.

We now consider these arguments in turn.