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 Tribunal held that the Appellant's CJRS claims were not calculated in accordance with the First Direction, as only salaries paid or payable by 19 March 2020 could be included in reference salary, and holiday pay not paid before that date was ineligible. The new contracts for employees were not effective for CJRS purposes as their first payment dates were after the relevant CJRS day. The Tribunal further held it had no jurisdiction to consider legitimate expectation or public law arguments. The Assessments were valid, in time, and correctly calculated under the legislation.

Citation
[2025] UKFTT 1403
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) Final Judgment
Outcome
Appeal dismissed
Legal Topics
Coronavirus Job Retention Scheme (cjrs), Income Tax Assessments, Statutory Interpretation, Legitimate Expectation, PAYE Real Time Information (rti), Employment Contracts, Holiday Pay, Jurisdiction of Tribunal
Tax Law Administrative Law Public Law Coronavirus Job Retention Scheme (cjrs) Income Tax Assessments Statutory Interpretation Legitimate Expectation PAYE Real Time Information (rti) +3 more

Case Brief

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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) Final 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)
  3. 3 Whether the correct Treasury Direction was applied

Ratio Decidendi

The Tribunal held that the Appellant's CJRS claims were not calculated in accordance with the First Direction, as only salaries paid or payable by 19 March 2020 could be included in reference salary, and holiday pay not paid before that date was ineligible. The new contracts for employees were not effective for CJRS purposes as their first payment dates were after the relevant CJRS day. The Tribunal further held it had no jurisdiction to consider legitimate expectation or public law arguments. The Assessments were valid, in time, and correctly calculated under the legislation.

Court Disposition

Appeal dismissed

Orders

  • The Assessments raised by HMRC are confirmed and stand good.
  • No reduction or variation of the Assessments is ordered.