Raystra Healthcare Limited v The Commissioners for HMRC
Decision date: 12 June 2023
Neutral citation: [2023] UKFTT 496 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
Raystra Healthcare appealed an HMRC assessment seeking recovery of Coronavirus Job Retention Scheme (CJRS) payments made in respect of six employees on the ground that payroll software had left RTI submissions in "test" mode so no RTI had been filed on or before 19 March 2020. The Tribunal found the statutory RTI requirement for CJRS entitlement was not met, rejected any exception for third‑party/software fault, reduced the assessment to £15,170.48 and otherwise dismissed the appeal; late permission to appeal was granted.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
For the CJRS period in issue, entitlement required that a payment of earnings to the employee was shown in an RTI return made on or before 19 March 2020; the absence of an express provision allowing relief for failures to submit RTI (including where caused by third‑party or software fault) means no such exception exists, and subsequent RTI filings after that date do not cure the absence for CJRS entitlement.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal expressed sympathy for the appellant’s circumstances but made clear that sympathy does not alter statutory interpretation or entitlement; it also noted that previous First‑tier Tribunal decisions have reached the same conclusion on the absence of an exception for failures to submit RTI by the relevant date.