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Am I the only one to be worried?
Key points
- Fresh Consulting was decided in the absence of the taxpayer.
- Since the CJRS is not a tax a Sch 36 Notice cannot apply.
- What is the basis for HMRC contemplating making a discovery that an amount which ought to have been assessed to tax had not been assessed?
I like tax cases. They reveal the human side of the tax legislation.
I read an article recently which indicated that the First-tier Tribunal decision in Fresh Consulting and Support Ltd (TC8606) was the first case on coronavirus job retention scheme (CJRS) payments. So I looked up the case. Having done so I find it a worrying decision for a number of reasons. It involved an appeal against a FA 2008 Sch 36 notice.
My first worry is that it was decided in the absence of the taxpayer. Of course a lot of cases are so decided ...
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