Category: First Tier Tax Tribunal

EIS relief, Enterprise Investment Scheme, HMRC tax appeals, qualifying trade, Upper Tribunal, First-tier Tax Tribunal, tax litigation, York SD Limited, Putney Power, EIS qualifying business activity, tax disputes solicitors, income tax relief withdrawal

York SD Ltd and Others v HMRC: What the Rooftop Solar EIS Appeal Means for Investors and Companies

The Upper Tribunal has granted partial permission to appeal in York SD Limited and Others v HMRC, a case examining whether a single rooftop solar panel installation could satisfy the EIS “qualifying business activity” requirement before six companies scaled up into much larger overseas solar projects. We break down the tribunal’s reasoning, the high bar for challenging findings of fact, and what the decision, read alongside Putney Power v HMRC, means for companies and investors relying on EIS relief.

Ultimate Guide to HMRC Discovery Assessments: How to Challenge & Appeal (2026)

HMRC discovery assessments can arrive years after you filed, but many are successfully challenged. This guide explains the legal framework, grounds of appeal, and how to protect your position in 2026.

VAT De-Registration Appeals

VAT De-Registration Appeals: How to Challenge HMRC’s Decision to Cancel Your VAT Number

If HMRC has cancelled your VAT number, urgent action is required. This guide explains how to challenge an HMRC de-registration decision through the internal review process and the First-tier Tax Tribunal, and why early legal advice is critical.

HMRC, Security Notice, Notice of Requirement, NOR, Tax Tribunal, Lexlaw, Tax Disputes, Director Liability, VAT Security, PAYE Security, Revenue Protection, Michael Duma, Harriot Rockey, Keith Gordon, Tax Litigation Solicitors.

Case Study: HMRC Security Notices Overturned – Duma & Rockey v HMRC (Tax Tribunal Appeal)

We are the leading firm representing Directors and Companies facing HMRC Security Notices and we regularly succeed on behalf of clients. Here, our counsel successfully fought HMRC Security Notices that sought to impose over £215,000 in personal liability for VAT and PAYE debts. The case is a landmark victory against HMRC Notices of Requirement to give Security.

Missing your HMRC tax tribunal appeal deadline doesn't mean your case is over. The Upper Tribunal's landmark decision in Medpro v HMRC fundamentally changed how tribunals approach late appeals, moving away from the strict Martland framework that previously barred most out-of-time applications. Today, tribunals weigh all circumstances equally—delay length, reasons for lateness, and your case's strength—rather than treating deadlines as near-absolute barriers. This shift opens new pathways for taxpayers with meritorious claims, but success depends on understanding the evolving rules and acting strategically. This guide explains the current tribunal landscape and your practical options.

Late HMRC Tax Tribunal Appeals: Medpro, Martland & Your Options

Under the old Martland rules missing a tax tribunal appeal deadline meant case closure as time limits were treated as virtually absolute. The Upper Tribunal’s 2025 decision in Medpro v HMRC restores judicial discretion and elevates case merits. Taxpayers with credible explanations now have a realistic path to rescuing late appeals. Understanding the shift and presenting your circumstances effectively to a tribunal, could mean the difference between recovering a valid claim and losing it permanently.