Letter Workshop Ltd v Revenue and Customs (INCOME TAX - Coronavirus Job Retention Scheme) [2025] UKFTT 1403 (TC) (24 November 2025)

Letter Workshop Ltd v Revenue and Customs (INCOME TAX - Coronavirus Job Retention Scheme) [2025] UKFTT 1403 (TC) (24 November 2025)

The appellant's CJRS claims exceeded the qualifying costs permitted by the First Direction because reference salaries were calculated using salaries not paid or payable by 19 March 2020 and included ineligible holiday pay. The Tribunal is bound to apply the statutory scheme and cannot consider arguments based on HMRC guidance or legitimate expectation. The assessments were valid, in time, and correctly calculated under the relevant law.

Citation
[2025] UKFTT 1403 (TC)
Parties
Appellant: Letter Workshop Ltd; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
24 November 2025
Procedural Posture
Tax Appeal / First Tier Tribunal (tax Chamber) Judgment
Outcome
Appeal dismissed
Legal Topics
Coronavirus Job Retention Scheme, Income Tax Assessments, Statutory Interpretation, Legitimate Expectation, PAYE Regulations, HMRC Guidance
Tax Law Administrative Law Public Law Coronavirus Job Retention Scheme Income Tax Assessments Statutory Interpretation Legitimate Expectation PAYE Regulations +1 more

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Parties

Letter Workshop Ltd

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal (tax Chamber) Judgment

Legal Issues

  1. 1 Whether the assessments raised under paragraph 9 of Schedule 16 to the Finance Act 2020 are valid and in time
  2. 2 Whether the appellant satisfied the conditions of paragraphs 5, 7 and 8 of the First Direction (CJRS) for the relevant employees
  3. 3 Whether the reference salary and qualifying costs were correctly calculated under the CJRS

Ratio Decidendi

The appellant's CJRS claims exceeded the qualifying costs permitted by the First Direction because reference salaries were calculated using salaries not paid or payable by 19 March 2020 and included ineligible holiday pay. The Tribunal is bound to apply the statutory scheme and cannot consider arguments based on HMRC guidance or legitimate expectation. The assessments were valid, in time, and correctly calculated under the relevant law.

Court Disposition

Appeal dismissed

Orders

  • The assessments raised by HMRC under paragraph 9 of Schedule 16 to the Finance Act 2020 stand and are confirmed.