Laxzo Ltd v Revenue and Customs (CORONAVIRUS JOB RETENTION SCHEME- Whether claims for payments under the CJRS were correctly calculated - whether claims had to refer to those employees shown on a Real Time Information return on or before 19 March 2020 - whether the assessments should be reduced - Para. 5, 7 and 8 of the Coronavirus Act 2022 Functions of Her Majesty's Revenue & Customs (Coronavirus Job Retention Scheme) Directions and para. 8, 9 and 11, Schedule 16 Finance Act 2020) [2025] UKFTT 372 (TC) (27 March 2025)

Laxzo Ltd v Revenue and Customs (CORONAVIRUS JOB RETENTION SCHEME- Whether claims for payments under the CJRS were correctly calculated - whether claims had to refer to those employees shown on a Real Time Information return on or before 19 March 2020 - whether the assessments should be reduced - Para. 5, 7 and 8 of the Coronavirus Act 2022 Functions of Her Majesty's Revenue & Customs (Coronavirus Job Retention Scheme) Directions and para. 8, 9 and 11, Schedule 16 Finance Act 2020) [2025] UKFTT 372 (TC) (27 March 2025)

The Appellant's CJRS claims were based on increased salaries not reflected in RTI returns on or before 19 March 2020, contrary to the statutory requirements. HMRC's assessment, reduced to £80,744.39, was correct, competent, and in time. The Tribunal has no jurisdiction to grant relief based on fairness or operational hardship; only statutory compliance is relevant.

Citation
[2025] UKFTT 372
Parties
Appellant: Laxzo Ltd; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
27 March 2025
Procedural Posture
Tax Appeal / First Tier Tribunal (tax Chamber) Final Decision
Outcome
Appeal dismissed
Legal Topics
Coronavirus Job Retention Scheme (cjrs), Income Tax Assessment, PAYE Real Time Information (rti), Corporation Tax, Statutory Interpretation, HMRC Powers, Procedural Fairness
Tax Law Administrative Law Coronavirus Job Retention Scheme (cjrs) Income Tax Assessment PAYE Real Time Information (rti) Corporation Tax Statutory Interpretation HMRC Powers +1 more

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Parties

Laxzo Ltd

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

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

Legal Issues

  1. 1 Whether HMRC's assessment was correct, competent, and in time
  2. 2 Whether the Appellant satisfied the conditions of the Coronavirus Direction for CJRS claims

Ratio Decidendi

The Appellant's CJRS claims were based on increased salaries not reflected in RTI returns on or before 19 March 2020, contrary to the statutory requirements. HMRC's assessment, reduced to £80,744.39, was correct, competent, and in time. The Tribunal has no jurisdiction to grant relief based on fairness or operational hardship; only statutory compliance is relevant.

Court Disposition

Appeal dismissed

Orders

  • Assessment for year ending 5 April 2021 reduced to £80,744.39 under section 50(6) TMA 1970
  • Appellant's appeal dismissed