Steven Anthony Lefort v The Commissioners for HMRC
Decision date: 17 October 2024
Neutral citation: [2024] UKFTT 926 (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 appeal concerned HMRC's 2018 revocation of the appellant's Fixed Protection 2014 certificate after his former employer made a payment into his Standard Life SIPP on 5 May 2014. The Tribunal found that the 5 May 2014 payment was a "relevant contribution" causing benefit accrual under para.1(3) of Schedule 22 and that HMRC were entitled to revoke the FP 2014 certificate under reg.11(a). The Tribunal also held it did not have jurisdiction to grant rescission or to review HMRC's discretionary remedies beyond determining compliance with the regulations. The appeal was dismissed.
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 binding reasoning is that a payment by a (former) employer into a registered money‑purchase arrangement that remains held for benefits constitutes a "relevant contribution" (para.14(1)(b), Schedule 36) and can give rise to benefit accrual under para.1(4)(a) of Schedule 22, permitting HMRC to revoke Fixed Protection under reg.11(a); and the First‑tier Tribunal's role is limited to deciding whether revocation/replacement complied with the FP 2014 Regulations (reg.12(3)), not to exercise equitable rescission or supervise HMRC's discretion beyond that statutory 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 Tribunal observed that rescission of mistaken payments is an equitable remedy for courts (e.g. the High Court) and the FTT should not treat payments as rescinded in the absence of such an order. It also noted that ordinary statutory terms like "contribution" and "payment" should be given a practical meaning and that lack of contractual entitlement does not automatically negate a statutory "relevant contribution" where funds remain held for benefits.