Dapetz Ltd v Revenue and Customs (CORONAVIRUS JOB RETENTION SCHEME - Whether claims for payments under the CJRS were correctly calculated) [2025] UKFTT 1096 (TC) (12 September 2025)

Dapetz Ltd v Revenue and Customs (CORONAVIRUS JOB RETENTION SCHEME - Whether claims for payments under the CJRS were correctly calculated) [2025] UKFTT 1096 (TC) (12 September 2025)

The Appellant's claims for CJRS payments were not calculated in accordance with the statutory requirements of the Coronavirus Direction. HMRC's revised assessments were correct and issued in time. The Tribunal has no jurisdiction to consider arguments based on fairness, legitimate expectation, or HMRC's Charter.

Citation
[2025] UKFTT 1096
Parties
Appellant: DAPETZ LIMITED; Respondents: THE COMMISSIONERS FOR HIS MAJESTY'S REVENUE AND CUSTOMS
Jurisdiction
United Kingdom
Judgment Date
12 September 2025
Procedural Posture
Tax Appeal / First Tier Tribunal Judgment
Outcome
Appeal dismissed
Legal Topics
Coronavirus Job Retention Scheme, Income Tax Assessments, Statutory Interpretation, Jurisdiction of Tribunal
Tax Law Public Law Coronavirus Job Retention Scheme Income Tax Assessments Statutory Interpretation Jurisdiction of Tribunal

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Parties

DAPETZ LIMITED

Appellant

THE COMMISSIONERS FOR HIS MAJESTY'S REVENUE AND CUSTOMS

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal Judgment

Legal Issues

  1. 1 Whether the Appellant correctly calculated claims for Coronavirus Job Retention Scheme payments
  2. 2 Whether HMRC's assessments were correct, competent, and in time
  3. 3 Whether the Appellant satisfied the conditions of the Coronavirus Direction

Ratio Decidendi

The Appellant's claims for CJRS payments were not calculated in accordance with the statutory requirements of the Coronavirus Direction. HMRC's revised assessments were correct and issued in time. The Tribunal has no jurisdiction to consider arguments based on fairness, legitimate expectation, or HMRC's Charter.

Court Disposition

Appeal dismissed

Orders

  • Assessments reduced to £177,401.27 as per HMRC's review letter
  • No further relief granted