UT (Tax & Chancery) UT-2024-000098 - [2025] UKUT 00247 (TCC)

UT (Tax & Chancery) Case Number: UT-2024-000098

Hearing venue: The Rolls Building

London EC4A 1NL

Judgment date: 23 July 2025

INCOME TAX –– FTT erred in deciding Respondent was entitled to coronavirus support payments pursuant to the Self-Employment Income Support Scheme “SEISS” – Respondent was not a qualifying person at the relevant time because he was not self-employed but a director or employee of a limited company which was trading - HMRC’s appeal allowed – FTT Decision set aside and remade confirming HMRC’s assessment to recover the payments

Before

JUDGE RUPERT JONES

JUDGE VIMAL TILAKAPALA

Between

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Appellants

And

MARC GUNNARSSON

Respondent

Representation:

For the Appellants: Ms Laura Inglis of counsel instructed by the General Counsel and Solicitor for His Majesty’s Revenue and Customs

The Respondent appeared in person