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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Dreyer v Revenue and Customs (VAT - civil evasion penalty of almost £5m for dishonest behaviour)

Dreyer v Revenue and Customs (VAT - civil evasion penalty of almost £5m for dishonest behaviour) [2025] UKFTT 1336 (TC) (10 November 2025)

The tribunal refused a late VAT penalty appeal, holding that the 30-day time limit remained effective, no review was notified, and delay was unjustified.

• Vat evasion
• Civil penalties
• Late appeal
• Time limits
• Statutory review
• Bill of rights act 1689

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Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period)

Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period) [2025] UKFTT 893 (TC) (02 July 2025)

The appeal was late because no valid request for statutory review was made within the statutory or extended period. The Valentine's Day letter did not constitute a valid request for review. Reliance on an agent is not a good reason for the delay, and the circumstances do not justify granting permission for a late appeal.

Source excerpt

• Income tax
• Statutory review
• Late appeal
• Closure notice
• Tribunal procedure

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Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period)

Fireman v Revenue and Customs (INCOME TAX - appeal against a final closure notice - whether late - was a valid request for a statutory review made within the requisite time period) [2025] UKFTT 893 (TC) (02 July 2025)

The appeal was late because no valid or timely request for statutory review was made; the Valentine's Day letter did not constitute such a request when read objectively. Even if HMRC extended the deadline, the letter's content was insufficient. Reliance on an agent and confusion caused by HMRC's correspondence do not constitute good reasons for the delay. The statutory time limits must be respected, and permission for a late appeal is not justified on the facts.

Source excerpt

• Income tax
• Statutory review
• Appeal deadlines
• Late appeal
• Closure notice
• Section 49 tma

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Dual Homes And Land Ltd v Revenue and Customs (VAT - application for permission to bring a late appeal)

Dual Homes And Land Ltd v Revenue and Customs (VAT - application for permission to bring a late appeal) [2025] UKFTT 523 (TC) (08 May 2025)

The tribunal granted Dual Homes and Land Ltd permission to bring late VAT appeals, finding the delay serious but the reasons credible and the balance of prejudice in its favour.

• Vat
• Late appeal
• Tribunal procedure
• Input tax credit
• Statutory review
• Late-appeal

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Dual Homes And Land Ltd v Revenue and Customs (VAT - application for permission to bring a late appeal)

Dual Homes And Land Ltd v Revenue and Customs (VAT - application for permission to bring a late appeal) [2025] UKFTT 523 (TC) (08 May 2025)

The Tribunal granted Dual Homes and Land Ltd permission to bring a late VAT appeal, accepting its explanation for a delay of over five months.

• Vat
• Late appeal
• Tribunal procedure
• Input tax credit
• Statutory review
• Late-appeal

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Buckingham v Revenue and Customs (NCOME TAX AND CAPITAL GAINS TAX - Special Dividend from US company - HMRC discovery assessment on the basis that the Special Dividend was part income and part capital )

Buckingham v Revenue and Customs (NCOME TAX AND CAPITAL GAINS TAX - Special Dividend from US company - HMRC discovery assessment on the basis that the Special Dividend was part income and part capital ) [2023] UKFTT 358 (TC) (04 April 2023)

The tribunal held that a US special dividend was partly income and partly capital, upheld HMRC’s original discovery assessment, and refused to increase it.

• Income tax
• Capital gains tax
• Foreign dividends
• Discovery assessment
• Statutory review
• Time limits

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Buckingham v Revenue and Customs (NCOME TAX AND CAPITAL GAINS TAX - Special Dividend from US company - HMRC discovery assessment on the basis that the Special Dividend was part income and part capital )

Buckingham v Revenue and Customs (NCOME TAX AND CAPITAL GAINS TAX - Special Dividend from US company - HMRC discovery assessment on the basis that the Special Dividend was part income and part capital ) [2023] UKFTT 358 (TC) (04 April 2023)

The tribunal held that a US special dividend was partly income and partly capital, upheld HMRC’s original discovery assessment, and refused to increase it.

• Income tax
• Capital gains tax
• Foreign dividends
• Discovery assessment
• Statutory review
• Capital/income distinction

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MAQSOOD HUSSAIN (t/a NISA LOCAL) v Revenue & Customs (VAT - three Notices of Appeal on same issue)

MAQSOOD HUSSAIN (t/a NISA LOCAL) v Revenue & Customs (VAT - three Notices of Appeal on same issue) [2023] UKFTT 40 (TC) (13 January 2023)

The Tribunal refused a late reinstatement of a withdrawn VAT appeal and refused late appeals against penalties and a 2016 review decision, finding no jurisdiction and no good reason for delay.

• Tribunal jurisdiction
• Late appeal
• Reinstatement of withdrawn appeal
• Penalties
• Statutory review
• Error correction

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