Citycom Systems Ltd v The Commissioners for HMRC
Decision date: 17 July 2025
Neutral citation: [2025] UKFTT 862 (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
Citycom Systems Ltd appealed HMRC assessments totalling £37,884.88 seeking to recover alleged overclaimed Coronavirus Job Retention Scheme (CJRS) payments for two director-employees. The Tribunal found Citycom's calculation method did not comply with the Coronavirus Direction, accepted HMRC’s RTI-based reference pay calculations (£690 for Amjad Khan; £330 and £600 for Rehman Khan for relevant periods), and dismissed the appeal, upholding the assessments as competent and in time.
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 decision turns on applying the statutory methods in the Coronavirus Direction and RTI data to calculate reference salary for CJRS entitlement; where claim amounts do not conform to those prescribed methods, HMRC may assess recoverable overpayments under Schedule 16 FA 2020 and such assessments are proper if raised within the statutory time limits.
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 observed that taxpayer failure to consult published guidance or seek advice was problematic and that HMRC’s procedural delays or refusal to provide “test data” did not remove the taxpayer’s obligation to ensure claims complied with the Direction; comments on HMRC’s general “process now, check later” approach were noted but not determinative.