Furlong Services Limited v The Commissioners for HMRC

Furlong Services Limited v The Commissioners for HMRC

The application for extension of time was refused because the delay was serious and significant, there was no good reason for the delay, and the Appellant’s solicitors’ repeated procedural errors and disregard for rules could not be excused. The prejudice to HMRC and the administration of justice outweighed any prejudice to the Appellant, and there were no strong merits to the underlying appeal given the statutory bar on appeals from the FTT’s decision.

Parties
Appellant: Furlong Services Limited; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
05 May 2026
Procedural Posture
Application for Extension of Time to Seek Permission to Appeal (tax and Chancery) / Upper Tribunal (tax and Chancery Chamber) Application for Extension of Time Following Refusal of Permission to Appeal by FTT
Outcome
Application for extension of time refused
Legal Topics
Extension of Time, Permission to Appeal, Information Notice, Finality of Tribunal Decisions
Tax Law Civil Procedure Extension of Time Permission to Appeal Information Notice Finality of Tribunal Decisions

Case Brief

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Parties

Furlong Services Limited

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Application for Extension of Time to Seek Permission to Appeal (tax and Chancery) / Upper Tribunal (tax and Chancery Chamber) Application for Extension of Time Following Refusal of Permission to Appeal by FTT

Legal Issues

  1. 1 Whether the Appellant should be granted an extension of time to seek permission to appeal to the Upper Tribunal
  2. 2 Whether there is a right of appeal from the FTT’s decision under paragraph 32(5) Schedule 36 Finance Act 2008

Ratio Decidendi

The application for extension of time was refused because the delay was serious and significant, there was no good reason for the delay, and the Appellant’s solicitors’ repeated procedural errors and disregard for rules could not be excused. The prejudice to HMRC and the administration of justice outweighed any prejudice to the Appellant, and there were no strong merits to the underlying appeal given the statutory bar on appeals from the FTT’s decision.

Court Disposition

Application for extension of time refused

Orders

  • The Extension Application is refused.
  • The Upper Tribunal is required by Rule 21(6) not to admit the application for permission to appeal.