Ross Michael Coates & Anor v The Commissioners for HMRC
Decision date: 15 May 2026
Neutral citation: [2026] UKFTT 723 (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 case concerns RCS's application to bar HMRC for deliberately failing to comply with a Tribunal direction requiring both parties to serve listing information on the Tribunal and each other. The Tribunal found HMRC deliberately breached the direction and that the conduct was serious, but dismissed the barring application as disproportionate because RCS suffered no real prejudice and the substantive hearing was listed as intended. The substantive appeal therefore remains listed; RCS may seek permission to appeal.
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
Deliberate non‑compliance with a Tribunal direction constitutes a serious breach and a breach of the duty to cooperate under the Tribunal rules; however, even a serious breach does not automatically justify the ultimate sanction of barring a party where the breach has caused no real prejudice and the purpose of the direction (here, effecting the listing of the substantive hearing) has been fulfilled.
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 judgment suggests that a party who believes a direction is open to abuse should apply to vary it rather than ignore it, and that a late apology for deliberate non‑compliance carries little weight in mitigation.