Cotton v Revenue and Customs (Coronavirus Pandemic - Self Employment Income Support Scheme) [2025] UKFTT 1398 (TC) (20 November 2025)

Cotton v Revenue and Customs (Coronavirus Pandemic - Self Employment Income Support Scheme) [2025] UKFTT 1398 (TC) (20 November 2025)

The appellant's 2019/20 tax return showed only employment as a seafarer and a claim for SED, with no self-employment income. SEISS eligibility requires self-employment with profits chargeable under Part 2 ITTOIA 2005. No evidence was provided to displace the tax return's contents. Therefore, the appellant was not eligible for SEISS, and HMRC's assessment to recover the payments was valid, in time, and for the correct amount.

Citation
[2025] UKFTT 1398
Parties
Appellant: Daniel Cotton; Respondents: The Commissioners for HM Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
20 November 2025
Procedural Posture
Tax Appeal / First Tier Tribunal (tax Chamber) Final Judgment
Outcome
Appeal dismissed
Legal Topics
Self Employment Income Support Scheme (seiss), Coronavirus Support Payments, Eligibility for SEISS, Income Tax Assessment, Employment Status, Seafarers Earnings Deduction (sed)
Tax Law Public Law Self Employment Income Support Scheme (seiss) Coronavirus Support Payments Eligibility for SEISS Income Tax Assessment Employment Status Seafarers Earnings Deduction (sed)

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Parties

Daniel Cotton

Appellant

The Commissioners for HM Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal (tax Chamber) Final Judgment

Legal Issues

  1. 1 Whether the appellant was self-employed and eligible for SEISS grants in 2019/20
  2. 2 Whether HMRC's assessment to recover SEISS payments was valid and in time

Ratio Decidendi

The appellant's 2019/20 tax return showed only employment as a seafarer and a claim for SED, with no self-employment income. SEISS eligibility requires self-employment with profits chargeable under Part 2 ITTOIA 2005. No evidence was provided to displace the tax return's contents. Therefore, the appellant was not eligible for SEISS, and HMRC's assessment to recover the payments was valid, in time, and for the correct amount.

Court Disposition

Appeal dismissed

Orders

  • Assessment of £8,352.00 upheld in full
  • Right to apply for permission to appeal within 56 days