Citycom Systems Ltd v Revenue and Customs (INCOME TAX - assessments - Coronavirus Job Retention Scheme support payments - Coronavirus Direction 15 April 2020 - para 9 of schedule 16 to the Finance Act 2020 - sections 34 and 36 Taxes Management Act 1970 - whether payments claimed were excessive) [2025] UKFTT 862 (TC) (17 July 2025)

Citycom Systems Ltd v Revenue and Customs (INCOME TAX - assessments - Coronavirus Job Retention Scheme support payments - Coronavirus Direction 15 April 2020 - para 9 of schedule 16 to the Finance Act 2020 - sections 34 and 36 Taxes Management Act 1970 - whether payments claimed were excessive) [2025] UKFTT 862 (TC) (17 July 2025)

The Appellant's CJRS claims were not calculated in accordance with the Coronavirus Direction, as the amounts claimed did not reflect the reference salary based on RTI data. HMRC's assessments were correct, competent, and issued within the statutory time limits. The Appellant failed to demonstrate that it had been overcharged or that HMRC's calculations were incorrect. Responsibility for accurate claims lay with the Appellant, not HMRC.

Citation
[2025] UKFTT 862
Parties
Appellant: Citycom Systems Ltd; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
17 July 2025
Procedural Posture
Tax Appeal / First Tier Tribunal (tax Chamber) Judgment
Outcome
Appeal dismissed
Legal Topics
Income Tax, Coronavirus Job Retention Scheme (cjrs), Statutory Interpretation, Tax Assessments, HMRC Powers
Tax Law Administrative Law Income Tax Coronavirus Job Retention Scheme (cjrs) Statutory Interpretation Tax Assessments HMRC Powers

Case Brief

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Parties

Citycom Systems Ltd

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal (tax Chamber) Judgment

Legal Issues

  1. 1 Whether the CJRS payments claimed by the Appellant were excessive and not in accordance with the Coronavirus Direction
  2. 2 Whether HMRC's assessments were correct, competent, and in time under the relevant statutory provisions

Ratio Decidendi

The Appellant's CJRS claims were not calculated in accordance with the Coronavirus Direction, as the amounts claimed did not reflect the reference salary based on RTI data. HMRC's assessments were correct, competent, and issued within the statutory time limits. The Appellant failed to demonstrate that it had been overcharged or that HMRC's calculations were incorrect. Responsibility for accurate claims lay with the Appellant, not HMRC.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.