Ruby Flooring Limited v The Commissioners for HMRC
Decision date: 4 July 2025
Neutral citation: [2025] UKFTT 821 (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
Ruby Flooring Ltd appealed HMRC assessments reclaiming alleged overclaimed Coronavirus Job Retention Scheme payments for two director-employees. The Tribunal held the correct CJRS reference salary is the amount shown in the latest RTI FPS filed on or before 19 March 2020 (£512), rejected the appellant's legitimate expectation/unfairness argument for lack of jurisdiction, dismissed the appeal and varied the assessments to HMRC's revised totals totalling £48,489.94.
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
For CJRS fixed-rate employees, the reference salary is the amount communicated to HMRC by RTI in the latest Full Payment Submission on or before the relevant CJRS cut-off date (here, 19 March 2020); the Tribunal’s jurisdiction is limited to statutory powers under TMA and Schedule 16 FA 2020 and does not permit allowing appeals based on legitimate expectation or general unfairness.
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 observes that RTI Business Objects reports accurately reflect taxpayer-filed data and, in this case, were not shown to be systemically erroneous; and that bank statements or irregular miscellaneous payments alone do not displace RTI-recorded reference salary for CJRS calculations. These comments appear as non-essential observations rather than binding holdings.