Purple Pay Ltd v Revenue and Customs (PROCEDURE - partial strike-out application - whether jurisdiction) [2026] UKFTT 625 (TC) (24 April 2026)

Purple Pay Ltd v Revenue and Customs (PROCEDURE - partial strike-out application - whether jurisdiction) [2026] UKFTT 625 (TC) (24 April 2026)

The Tribunal has no jurisdiction to consider challenges to the validity of the stop notice itself; the only competent appeals are against the penalty and the JSLN. The disputed grounds of appeal (company ceased trading, no responsible person, no breach) are bad in law, have no realistic prospect of success, and amount to an abuse of process. They must be struck out under Rule 8.

Citation
[2026] UKFTT 625
Parties
First Appellant: Purple Pay Limited; Second Appellant: Dennis Fenemore; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
24 April 2026
Procedural Posture
Tax Appeal (first Tier Tribunal, Tax Chamber) / Partial Strike Out Application Prior to Substantive Hearing
Outcome
Application granted; partial strike-out ordered.
Legal Topics
Stop Notice Penalties, Joint and Several Liability Notices, Tribunal Jurisdiction, Strike Out Applications, Reasonable Excuse Defence, Abuse of Process
Tax Law Administrative Law Stop Notice Penalties Joint and Several Liability Notices Tribunal Jurisdiction Strike Out Applications Reasonable Excuse Defence Abuse of Process

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 11 Party arguments 2 Amounts and remedies 6
Sign in to unlock

Parties

Purple Pay Limited

First Appellant

Dennis Fenemore

Second Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (first Tier Tribunal, Tax Chamber) / Partial Strike Out Application Prior to Substantive Hearing

Legal Issues

  1. 1 Whether the Tribunal has jurisdiction to consider challenges to the validity of a stop notice under FA 2014
  2. 2 Whether certain grounds of appeal have a reasonable prospect of success
  3. 3 Whether the grounds amount to an abuse of process

Ratio Decidendi

The Tribunal has no jurisdiction to consider challenges to the validity of the stop notice itself; the only competent appeals are against the penalty and the JSLN. The disputed grounds of appeal (company ceased trading, no responsible person, no breach) are bad in law, have no realistic prospect of success, and amount to an abuse of process. They must be struck out under Rule 8.

Court Disposition

Application granted; partial strike-out ordered.

Orders

  • The disputed grounds of appeal are struck out under Rule 8.
  • Parties to lodge agreed directions for further progress of the appeals by 22 May 2026, or HMRC to lodge draft directions if no agreement.