Glo-ball Group Ltd V Revenue And Customs (INCOME TAX - Coronavirus Job Retention Scheme) [2023] UKFTT 435 (TC) (19 April 2023)

Glo-ball Group Ltd V Revenue And Customs (INCOME TAX - Coronavirus Job Retention Scheme) [2023] UKFTT 435 (TC) (19 April 2023)

Social media posts made by the appellant’s director during the relevant periods constituted 'work' as they were intended to maintain or enhance the business’s goodwill and future revenue potential. As a result, the director had not ceased all work for 21 consecutive days, and the appellant was not entitled to claim...

Source-derived case information.

Citation
[2023] UKFTT 435
Parties
Appellant: Glo-ball Group Limited; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
19 April 2023
Procedural Posture
Income Tax Appeal (coronavirus Job Retention Scheme) / First Tier Tribunal (tax Chamber) Substantive Judgment
Outcome
Appeal dismissed
Legal Topics
Coronavirus Job Retention Scheme, Furlough Eligibility, Income Tax Assessments, Employment Status, HMRC Powers
Tax Law Employment Law Administrative Law Coronavirus Job Retention Scheme Furlough Eligibility Income Tax Assessments Employment Status HMRC Powers

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Parties

Glo-ball Group Limited

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal (coronavirus Job Retention Scheme) / First Tier Tribunal (tax Chamber) Substantive Judgment

Legal Issues

  1. 1 Whether social media posts by a director during furlough constituted 'work' under the Coronavirus Job Retention Scheme
  2. 2 Whether the appellant was entitled to support payments under the Scheme for the relevant periods

Ratio Decidendi

Social media posts made by the appellant’s director during the relevant periods constituted 'work' as they were intended to maintain or enhance the business’s goodwill and future revenue potential. As a result, the director had not ceased all work for 21 consecutive days, and the appellant was not entitled to claim support payments under the Scheme for those periods. The assessments by HMRC were therefore upheld.

Court Disposition

Appeal dismissed

Orders

  • Assessments by HMRC upheld
  • Appellant not entitled to support payments for the periods in question