Universal (Commercial) Ltd v Revenue & Customs [2012] UKFTT 467 (TC) (11 July 2012)

Universal (Commercial) Ltd v Revenue & Customs [2012] UKFTT 467 (TC) (11 July 2012)

The tribunal refused permission to appeal out of time because the appellant failed to provide a sufficient reason for the delay between March and July 2011, and the prospects of success in the substantive appeal were remote given the available evidence and the amounts assessed.

Citation
[2012] UKFTT 467 (TC)
Parties
Appellant: Universal (Commercial) Ltd; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
11 July 2012
Procedural Posture
Appeal (tax) / Application for Permission to Appeal Out of Time
Outcome
Permission to appeal out of time refused
Legal Topics
PAYE Determinations, Late Appeals, Tribunal Discretion, Reasonable Excuse, Regulation 80 PAYE Regulations 2003, Section 49 TMA 1970
Tax Law Administrative Law PAYE Determinations Late Appeals Tribunal Discretion Reasonable Excuse Regulation 80 PAYE Regulations 2003 Section 49 TMA 1970

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Parties

Universal (Commercial) Ltd

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Appeal (tax) / Application for Permission to Appeal Out of Time

Legal Issues

  1. 1 Whether the appellant should be granted permission to appeal out of time against PAYE determinations under regulation 80 of the PAYE Regulations 2003
  2. 2 Whether there was a reasonable excuse for the delay in appealing
  3. 3 Whether the prospects of success in the substantive appeal justified granting an extension

Ratio Decidendi

The tribunal refused permission to appeal out of time because the appellant failed to provide a sufficient reason for the delay between March and July 2011, and the prospects of success in the substantive appeal were remote given the available evidence and the amounts assessed.

Court Disposition

Permission to appeal out of time refused

Orders

  • No extension of time granted for appeal against PAYE determinations
  • No permission to appeal