Foy Wealth Limited v The Commissioners for HMRC
Decision date: 16 July 2026
Neutral citation: [2026] UKFTT 1061 (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
Foy Wealth Limited appealed HMRC's 2 July 2018 compulsory VAT registration, assessments and penalties but the First-tier Tribunal found no "conclusion date" for the statutory review had occurred because HMRC had not notified review conclusions. A 22 December 2025 insolvency witness statement was held not to constitute the required notification, so the appeal was premature and was struck out for want of jurisdiction; the substantive merits were not reached.
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 the statutory definition of "conclusion date" in G(7) as requiring an actual document notifying the conclusions of the review; a deemed conclusion under F(8) or documents produced in other proceedings do not satisfy G(7) unless they expressly perform the statutory notification function.
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 (without deciding further legal principle) that HMRC should take steps to comply with F(9) to notify a person of review conclusions where a valid review request exists, and commented that it would be unfair to enforce an assessment that carries no right of appeal while the underlying decision to register is still under challenge.
Warning
This chunk is repetitive and contains duplicated passages, but the core facts and reasoning are clear.