Green v Commissioners for His Majesty's Revenue and Customs (HICBC - Application to Make a Late Appeal) [2023] UKFTT 1006 (TC) (01 December 2023)

The delay of 1067 days was serious and significant; the reasons for delay were not sufficiently meritorious; balancing prejudice and statutory time limits, permission for a late appeal was refused.

Citation: [2023] UKFTT 1006 (TC)
Parties: Appellant: Clive Green; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction: United Kingdom
Judgment Date: 01 December 2023
Procedural Posture: Tax Appeal / Application for Permission to Make a Late Appeal
Outcome: Application for permission to make a late appeal refused
Legal Topics: High Income Child Benefit Charge, Discovery Assessments, Late Appeal, Judicial Discretion

Tax Law High Income Child Benefit Charge Discovery Assessments Late Appeal Judicial Discretion

Case Brief

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Full judgment text Downloadable case file Legal principles 2 Authorities cited 8 Party arguments 2 Amounts and remedies 4

Parties

Clive Green

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Application for Permission to Make a Late Appeal

Legal Issues

1 Whether permission should be granted for a late appeal against discovery assessments for HICBC

Ratio Decidendi

The delay of 1067 days was serious and significant; the reasons for delay were not sufficiently meritorious; balancing prejudice and statutory time limits, permission for a late appeal was refused.

Court Disposition

Application for permission to make a late appeal refused

Orders

Appellant's application to bring appeal against discovery assessments out of time is refused