Kingdom Travel Services Limited v The Commissioners for HMRC

Kingdom Travel Services Limited v The Commissioners for HMRC

The Appellant was only entitled to CJRS payments based on the reference salaries paid in the last pay period prior to 19 March 2020. Claims based on increased salaries were not permitted under the Treasury Directions. The assessments by HMRC were valid and within time. The appeal was dismissed.

Source-derived case information.

Parties
Appellant: Kingdom Travel Services Limited; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
08 June 2024
Procedural Posture
Tax Appeal / Judgment
Outcome
Appeal dismissed
Legal Topics
Coronavirus Job Retention Scheme, Statutory Interpretation, PAYE, Income Tax Assessment
Tax Law Administrative Law Coronavirus Job Retention Scheme Statutory Interpretation PAYE Income Tax Assessment

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Parties

Kingdom Travel Services Limited

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Judgment

Legal Issues

  1. 1 Whether the claims made to the Coronavirus Job Retention Scheme (CJRS) were made in accordance with the Treasury Directions
  2. 2 Whether the Appellant was entitled to CJRS payments based on increased salaries not reflected in the reference period

Ratio Decidendi

The Appellant was only entitled to CJRS payments based on the reference salaries paid in the last pay period prior to 19 March 2020. Claims based on increased salaries were not permitted under the Treasury Directions. The assessments by HMRC were valid and within time. The appeal was dismissed.

Court Disposition

Appeal dismissed