Intech Ventures Limited (in liquidation) & Anor v The Commissioners for HMRC
Decision date: 26 November 2025
Neutral citation: [2025] UKFTT 1444 (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
This preliminary Tribunal decision concerned late appeals by Intech Ventures Ltd (in liquidation) and its sole former director, Mr Michael Stefan Duma, against HMRC Notices of Requirement to give security for PAYE and NICs. The Tribunal found the Notices were served (on the civil standard), the 30-day appeal period ran from HMRC's "View of the Matter" letters, and the appeals (filed 214 days late) were thus out of time. The Tribunal waived a procedural Rule 20 defect but, applying the Martland/Denton balancing exercise, refused permission to admit the appeals out of time. Costs from an earlier barring application were reserved for separate written determination.
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
A certificate of service and evidence that HMRC followed its standard postal procedure can satisfy the civil standard that a notice was "given" by post absent persuasive contrary evidence; where HMRC issues a "View of the Matter" triggering the 30-day acceptance period under s49C TMA, appeals lodged outside that period require permission, which should be refused if the appellant cannot provide a satisfactory explanation under the relevant late-admission balancing test.
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 judge noted (non-bindingly) that lack of funds to instruct advisers ordinarily carries little weight in excusing delay, and observed that even giving greater weight to the importance of time limits would not have changed the outcome.