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 appeals against the issuance or validity of a stop notice unless a withdrawal request was made and refused within the statutory time limit, which did not occur. The disputed Grounds of Appeal—relating to cessation of business, lack of responsible persons, and absence of breach—are bad in law, have no reasonable prospect of success, and constitute an abuse of process. Accordingly, those parts of the appeal must be struck out under Rule 8 of the Tribunal Rules.

Citation
[2026] UKFTT 625 (TC)
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 Notice (jsln), Jurisdiction of Tribunal, Strike Out Applications, Reasonable Excuse Defence, Abuse of Process
Tax Law Administrative Law Stop Notice Penalties Joint and Several Liability Notice (jsln) Jurisdiction of Tribunal Strike Out Applications Reasonable Excuse Defence Abuse of Process

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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 certain Grounds of Appeal relating to the validity of the stop notice
  2. 2 Whether the disputed Grounds of Appeal have a reasonable prospect of success
  3. 3 Whether the application amounts to an abuse of process

Ratio Decidendi

The Tribunal has no jurisdiction to consider appeals against the issuance or validity of a stop notice unless a withdrawal request was made and refused within the statutory time limit, which did not occur. The disputed Grounds of Appeal—relating to cessation of business, lack of responsible persons, and absence of breach—are bad in law, have no reasonable prospect of success, and constitute an abuse of process. Accordingly, those parts of the appeal must be struck out under Rule 8 of the Tribunal Rules.

Court Disposition

Application granted; partial strike-out ordered.

Orders

  • The disputed Grounds of Appeal are struck out for lack of jurisdiction and/or no reasonable prospect of success and/or abuse of process.
  • Parties to lodge agreed Directions for further progress of the appeals by 22 May 2026, failing which HMRC to lodge Draft Directions.