Commissioners for HMRC v ZS Tech Solutions UK Limited

Decision date: 6 May 2025

Neutral citation: [2025] UKFTT 525 (TC)

Overall AI summary confidence: high

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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

This case concerns HMRC's application for a penalty under section 98(1)(b)(i) TMA after ZS Tech Solutions UK Limited failed to comply with a statutory information notice issued under the ITA and then failed to comply with Tribunal directions and an unless order. The Tribunal barred the company for non‑compliance, proceeded in its absence, and found the company liable to a £300 penalty for failing to furnish the requested information. The decision allows HMRC's application and records 56 days to seek permission to appeal.

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

The Tribunal treated non‑compliance with an unless order as automatically resulting in barring the respondent and permitting the Tribunal to proceed and determine the application in the respondent's absence; where a respondent fails to comply with a statutory information notice under the ITA, a penalty under section 98(1)(b)(i) TMA (up to £300) may be imposed once non‑compliance is established.

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 suggested that where a respondent offers no explanation or application to be reinstated, "the documents speak for themselves" and there is little likely to alter the outcome; it also emphasised that proceeding in the respondent's absence is appropriate where notification and reasonable steps to notify have been taken and it is in the interests of justice.