L W Joinery & Flooring Limited v The Commissioners for HMRC

Decision date: 22 October 2026

Neutral citation: [2026] UKFTT 1485 (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 appeal concerned whether the sole director's reference salary for CJRS purposes in the relevant period was £2,996 or £512. The Tribunal preferred contemporaneous RTI and payroll submissions (notably the 5 March 2020 RTI) over later payslips, bank entries and witness recollection, and found the Company did not prove the higher salary on the balance of probabilities. The appeal was dismissed and HMRC's assessments were upheld.

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: medium

The Tribunal applied a fact-finding approach that gives greater evidential weight to contemporaneous RTI submissions and payroll records than to later or retrospective records and witness testimony; where there is a conflict, the burden is on the taxpayer to prove contemporaneous records are incorrect on the balance of probabilities.

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 indicated that automated or administrative payments of CJRS, without more, do not create a legitimate expectation of a substantive entitlement to retain funds, and that alleged failures of HMRC’s duty of candour or acceptance of claims do not, by themselves, alter the evidential approach to determining entitlement.

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