W.Byers Limited v The Commissioners for HMRC
Decision date: 15 June 2026
Neutral citation: [2026] UKFTT 886 (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
W. Byers Ltd set up a Direct Debit, submitted its VAT return and received an unqualified on-screen HMRC confirmation stating "We will collect your payments automatically by Direct Debit", but HMRC did not collect the due payment on 7 November 2025. The Tribunal found it was reasonable for the company to rely on that specific HMRC representation, which amounted to a reasonable excuse and was remedied without unreasonable delay, and cancelled the 3% first late payment penalty of £4,848.54.
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 clear, specific and unqualified contemporaneous communication from HMRC that payments "will" be collected automatically can found a reasonable excuse where reliance on that statement was reasonable in the circumstances; such reliance may prevail notwithstanding broader published guidance that contains undisclosed procedural conditions.
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 noted the company director’s autism as part of the factual background but treated it as unnecessary to the decision. It also observed that while a prudent taxpayer might consult published guidance, the legal test is whether the taxpayer acted reasonably in the circumstances, not whether they took every possible precaution.