Letter Workshop Ltd v The Commissioners for HMRC
Decision date: 24 November 2025
Neutral citation: [2025] UKFTT 1403 (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 whether Letter Workshop Ltd correctly calculated employees’ reference salaries for CJRS claims and whether HMRC’s assessments were valid and in time. The First Direction governed calculation: fixed-rate employees’ reference pay is taken from the latest pay period ending on or before the CJRS day (19 March 2020) and variable-rate employees are subject to the look‑back/averaging rules; RTI filings and amounts payable as at that day are material. The Tribunal dismissed the appeal, reduced the original assessments under its s.50(6) TMA powers, and upheld the remainder.
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 ratio is that CJRS reference salary must be determined by the manner prescribed in the applicable Treasury Direction (the First Direction), with paras. 7.1–7.15 and para. 7.2 (averaging for variable pay) or para. 7.7 (fixed‑rate latest period ending on or before 19 March 2020) controlling; RTI-reported pay and the amounts payable as at the relevant CJRS day are material to that calculation. Alternative methods or reliance on HMRC guidance do not displace these statutory tests.
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 (obiter) that HMRC guidance and webchat answers do not override the statutory Direction, and that public‑law arguments such as legitimate expectation are principally matters for judicial review rather than the Tribunal’s TMA jurisdiction; on these facts any legitimate expectation argument failed.
Warning
Chunk contains extensive duplication and repeated passages which made extraction of a concise narrative more difficult. Notes contain extensive duplication and some repetition which made extraction more difficult; no other obvious factual omissions identified.