United Kingdom Case Law

Bridgeman v Revenue and Customs (Application for permission to appeal out of time; Martland principles applied; permission granted)

Bridgeman v Revenue and Customs (Application for permission to appeal out of time; Martland principles applied; permission granted) [2026] UKFTT 679 (TC) (07 May 2026)

The First-tier Tribunal granted Mr Bridgeman permission to bring a late tax appeal, finding his delay arose from a genuine procedural mistake and that the balance favoured permission.

• Late appeal
• Statutory review
• Closure notice
• Procedural requirements
• Late-appeal
• Tax-appeals

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Bridgeman v Revenue and Customs (Application for permission to appeal out of time; Martland principles applied; permission granted)

Bridgeman v Revenue and Customs (Application for permission to appeal out of time; Martland principles applied; permission granted) [2026] UKFTT 679 (TC) (07 May 2026)

The First-tier Tribunal granted permission for a late tax appeal, finding the appellant’s email reflected a genuine procedural mistake and that the balance favored relief.

• Late appeal
• Statutory review
• Closure notice
• Procedural requirements
• Late-appeal
• Tax-chamber

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Fender v Revenue and Customs (Application for permission to make late appeal to HMRC - Martland and Medpro considered and applied)

Fender v Revenue and Customs (Application for permission to make late appeal to HMRC - Martland and Medpro considered and applied) [2026] UKFTT 319 (TC) (26 February 2026)

The Tribunal refused permission for Andrew Fender to make late appeals against HMRC closure notices, finding delays of over four and five years were not justified.

• Late appeal
• Closure notice
• Judicial discretion
• Statutory time limits
• Late-appeal
• Closure-notice

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UI2025004804

UI2025004804 [2026] UKAITUR UI2025004804 (24 February 2026)

The Upper Tribunal upheld the First-tier Tribunal’s dismissal of an EEA family permit appeal, finding no proof that the appellant’s bundle was properly filed and no procedural unfairness.

• Eea family permit
• Procedural fairness
• Late appeal
• Service of evidence
• Immigration-law
• Procedural-fairness

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Ram v Revenue and Customs (Procedure - Application for permission to make a late appeal)

Ram v Revenue and Customs (Procedure - Application for permission to make a late appeal) [2026] UKFTT 249 (TC) (12 February 2026)

The First-tier Tribunal refused permission for a late VAT appeal, finding an 867-day delay, no good reason for it, and prejudice to finality and HMRC.

• Late appeal
• Tribunal procedure
• Vat penalties
• Company officer liability
• Statutory time limits
• Late-appeal

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Ram v Revenue and Customs (Procedure - Application for permission to make a late appeal)

Ram v Revenue and Customs (Procedure - Application for permission to make a late appeal) [2026] UKFTT 249 (TC) (12 February 2026)

The Tax Chamber refused permission for a late VAT appeal, finding a serious delay, inadequate reasons for it, and insufficient justification to override statutory time limits.

• Late appeal
• Tribunal procedure
• Vat penalties
• Company officer liability
• Statutory time limits
• Late-appeal

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Batten v Revenue and Customs (LATE APPEAL - former partner in a construction partnership - appeal by a partner who was not the nominated partner for tax purposes - assessed to tax on proceeds of disposal of properties acquired by the partnership)

Batten v Revenue and Customs (LATE APPEAL - former partner in a construction partnership - appeal by a partner who was not the nominated partner for tax purposes - assessed to tax on proceeds of disposal of properties acquired by the partnership) [2025] UKFTT 1538 (TC) (11 December 2025)

The tribunal granted a former partner permission to bring late appeals against partnership return amendments, a discovery assessment, and a penalty.

• Late appeal
• Partnership tax returns
• Discovery assessment
• Penalty assessment
• Appeal rights
• Hmrc procedures

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Batten v Revenue and Customs (LATE APPEAL - former partner in a construction partnership - appeal by a partner who was not the nominated partner for tax purposes - assessed to tax on proceeds of disposal of properties acquired by the partnership)

Batten v Revenue and Customs (LATE APPEAL - former partner in a construction partnership - appeal by a partner who was not the nominated partner for tax purposes - assessed to tax on proceeds of disposal of properties acquired by the partnership) [2025] UKFTT 1538 (TC) (11 December 2025)

The tribunal granted Jonathan Batten permission to bring late appeals in a partnership tax dispute, finding a good reason for delay on the partnership amendments and granting relief overall.

• Late appeal
• Partnership tax returns
• Discovery assessment
• Appeal rights
• Procedural fairness
• Late-appeal

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Balasingam v Revenue and Customs (STRIKE OUT - res judicata - whether appeal against personal liability notice was determined in the course of appeal by company against penalties)

Balasingam v Revenue and Customs (STRIKE OUT - res judicata - whether appeal against personal liability notice was determined in the course of appeal by company against penalties) [2025] UKFTT 1541 (TC) (02 December 2025)

Res judicata does not apply because the personal liability notice was not within the scope of the previous VAT appeal; neither the notice of appeal nor the statement of case addressed the requirements for personal liability notices. However, the appeal against the personal liability notice was filed over four years late, and the reasons for delay, including HMRC errors and adviser actions, do not constitute good reason. Permission for late appeal is refused.

Source excerpt

• Res judicata
• Personal liability notice
• Late appeal
• Vat penalties

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Balasingam v Revenue and Customs (STRIKE OUT - res judicata - whether appeal against personal liability notice was determined in the course of appeal by company against penalties)

Balasingam v Revenue and Customs (STRIKE OUT - res judicata - whether appeal against personal liability notice was determined in the course of appeal by company against penalties) [2025] UKFTT 1541 (TC) (02 December 2025)

The doctrine of res judicata does not bar the appeal because the scope of the previous VAT appeal did not extend to the personal liability notice; however, the appeal against the personal liability notice is out of time by over four years, and there is no good reason for the delay. The errors by HMRC do not justify the delay, and the prospects of success are exceedingly weak. Permission for a late appeal is refused.

Source excerpt

• Res judicata
• Personal liability notice
• Vat penalties
• Late appeal
• Abuse of process

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