Assembly Global Networks Ltd v The Commissioners for His Majesty’s Revenue and Customs [2025] UKUT 00023 (TCC)

Upper Tribunal Tax and Chancery decision of JUDGE RUPERT JONES on 16 December 2024

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
22 January 2025
Category:
Tax
Release date:
16 December 2024

Read full decision Assembly Global Networks Ltd v The Commissioners of His Majesty’s Revenue and Customs

  1. The Applicant, Assembly Global Networks Ltd (“AGN”), applies to the Upper Tribunal (Tax and Chancery) (“UT”) for permission to appeal the decision of the First-tier Tribunal (Tax Chamber) (“the FTT”), released on 3 April 2024 (“the Decision”). The appeal was decided by the FTT following a hearing conducted on 14 March 2024.
  2. The FTT decided a preliminary issue: whether HMRC’s Enquiry Letter dated 15 July 2022 had been received at AGN’s registered office by 31 July 2022, the last date on which HMRC were able to open a valid enquiry into AGN’s claim for a research and development credit contained in its amended Corporation Tax return.
  3. The Tribunal found in favour of HMRC stating its conclusion at [7] of the Decision:

Updates to this page

Published 22 January 2025