Steven Anthony Lefort v The Commissioners for HMRC

Steven Anthony Lefort v The Commissioners for HMRC

The Tribunal found that a relevant contribution was paid by the Appellant’s former employer after 6 April 2014, constituting benefit accrual and a protection-cessation event under the FP 2014 Regulations. HMRC was entitled to revoke the Fixed Protection certificate, and the Tribunal’s jurisdiction did not extend to granting rescission or reviewing HMRC’s discretion. The appeal was dismissed.

Parties
Appellant: Steven Anthony Lefort; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
21 October 2024
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Revocation of Fixed Protection 2014 Certificate, Registered Pension Schemes, Lifetime Allowance Transitional Protection, Doctrine of Mistake, Rescission, Tribunal Jurisdiction
Tax Law Pensions Law Administrative Law Revocation of Fixed Protection 2014 Certificate Registered Pension Schemes Lifetime Allowance Transitional Protection Doctrine of Mistake Rescission +1 more

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Parties

Steven Anthony Lefort

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether HMRC correctly revoked the Appellant’s Fixed Protection 2014 certificate under regulation 11(a) of the FP 2014 Regulations
  2. 2 Whether there was a protection-cessation event under paragraph 1(3) of the FP 2014 Regulations
  3. 3 Whether the First-tier Tribunal has jurisdiction to grant rescission or review HMRC’s discretion

Ratio Decidendi

The Tribunal found that a relevant contribution was paid by the Appellant’s former employer after 6 April 2014, constituting benefit accrual and a protection-cessation event under the FP 2014 Regulations. HMRC was entitled to revoke the Fixed Protection certificate, and the Tribunal’s jurisdiction did not extend to granting rescission or reviewing HMRC’s discretion. The appeal was dismissed.

Court Disposition

Appeal dismissed

Orders

  • No order for rescission
  • HMRC’s revocation of Fixed Protection 2014 certificate stands