Lindsey Prodger v The Commissioners for HMRC

Decision date: 20 October 2026

Neutral citation: [2026] UKFTT 1441 (TC)

Overall AI summary confidence: high

AI Notice: Any short overview, ratio decidendi summary or obiter dicta summary shown on this page is AI-generated, provided only to help users assess potential relevance more quickly, and may be wholly inaccurate. No liability is accepted for the accuracy of any such summary, regardless of any AI confidence rating shown. Users should check the underlying decision and obtain appropriate legal advice rather than relying on any summary.

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 an application for permission to bring a late appeal against HMRC assessments for the High Income Child Benefit Charge (HICBC) and associated failure-to-notify penalties. The Tribunal found a delay of over four years, concluded the Appellant had not shown good reasons for the delay, and refused permission to bring a late appeal; it also proceeded with the hearing in the Appellant's absence after finding reasonable steps had been taken to notify him. Some substantive HICBC issues had been resolved between the parties before the hearing.

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: medium

A late appeal will be refused where there is a very significant delay and the appellant cannot establish good reasons for that delay; additional factors such as non‑compliance with Tribunal directions and failure to attend hearings weigh against granting permission. No compelling countervailing circumstances were found here to justify extending time.

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 indicated it may properly take into account the modest monetary value of remaining disputed issues when assessing prejudice and the efficient conduct of litigation, and observed that lack of direct evidence (for example, a witness statement) to support assertions of not receiving key correspondence undermines claims of a reasonable excuse for delay.