Upper Tribunal Tax and Chancery Chamber

UT (Tax & Chancery) UT/ xx /20 xx - [2025] UKUT 00255 (TCC)

Fecha: 12-Jun-2025

Background

(1)

Background

By a decision dated 30 October 2023, following a two day hearing taking place on 18 and 20 October 2023, the First-Tier Tribunal (Tax Chamber) (the FTT) resolved a number of applications (the Decision). Three of the applications are material for present purposes:

(1)

Application TC/2022/13237. This was an application by Mr Kalvinder Ruprai for permission to bring a late appeal against a personal liability notice issued by HMRC making Mr Ruprai liable to pay 100% of a penalty issued to Aver Healthcare Limited (Aver).

(2)

Application TC/2022/13510. This was an application by Medpro Healthcare Limited (Medpro) for permission to bring a late appeal against a penalty issued by HMRC on 15 March 2022 and upheld by HMRC following review on 28 April 2022.

(3)

Application TC/2022/13511. This was an application by Mr Ruprai for permission to bring a late appeal against a personal liability notice issued by HMRC making Mr Ruprai liable to pay 100% of the penalty issued to Medpro.

The notice of appeal in Application 13237 (as we shall refer to the application at ([1(1)]) was submitted 70 days late; the notices of appeal in Application 13510 ([1(2)]) and Application 13511 ([1(3)])were each 5 months and 17 days late.

The penalties imposed were substantial: £43,698.19 in the case of Application 13237; and £1,019,538.26 in the case of Applications 13510 and 13511.