Assembly Global Networks Ltd v The Commissioners for His Majesty鈥檚 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

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  1. The Applicant, Assembly Global Networks Ltd (鈥淎GN鈥�), applies to the Upper Tribunal (Tax and Chancery) (鈥淯T鈥�) for permission to appeal the decision of the First-tier Tribunal (Tax Chamber) (鈥渢he FTT鈥�), released on 3 April 2024 (鈥渢he Decision鈥�). The appeal was decided by the FTT following a hearing conducted on 14 March 2024.
  2. The FTT decided a preliminary issue: whether HMRC鈥檚 Enquiry Letter dated 15 July 2022 had been received at AGN鈥檚 registered office by 31 July 2022, the last date on which HMRC were able to open a valid enquiry into AGN鈥檚 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