In Raystra Healthcare Ltd v HMRC [2023] UKFTT 496 (TC) (12 June 2023) the FTT found that claims under the Coronavirus job retention scheme (CJRS) must fail where the employees in question had not been included in an RTI return before the deadline. The scheme rules were clear and there was no discretion to make exceptions.
HMRC had issued an assessment to recover payments made to the taxpayer company under the CJRS in respect of six employees who had not been included in a real-time information (RTI) return before the 19 March 2020 deadline.
An upgrade to the taxpayer’s RTI software in November 2019 had left the system in ‘test’ mode causing it to stop sending RTI returns from that point until HMRC notified the taxpayer of the problem on 24 April 2020. The taxpayer submitted the missing RTI details on the same day and later applied for and...
