Parkside Nail Supplies Ltd v The Commissioners for HMRC
Decision date: 14 August 2025
Neutral citation: [2025] UKFTT 988 (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
Parkside appealed HMRC assessments denying CJRS claims for employee Hai Thanh Tran on the basis that PAYE earnings had not been reported in an RTI submission by the relevant date (19 March 2020). The First-tier Tribunal struck out the appeal under Rule 8(3)(c) as having no reasonable prospect of success, holding the absence of RTI reporting by that date was determinative of ineligibility and could not be displaced by arguments about technical failure, fairness or the scheme’s “spirit.”
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
Where Treasury Directions require that an employee’s earnings be included in an RTI PAYE submission by a specified CJRS date, failure to have those earnings reported by that date is determinative of ineligibility for the CJRS; the Tribunal has no jurisdiction to excuse non‑compliance with that clear statutory/Treasury Directions requirement.
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 expressed sympathy for the appellant’s circumstances but indicated that such considerations cannot permit departure from the statutory scheme; it also reiterated reliance on prior FTT decisions treating RTI reporting as a bright‑line eligibility test.
Warning
- The chunk contains duplicated and repeated passages which make it somewhat noisy to read. The provided notes contain duplicated and repeated passages and may be somewhat noisy, but they include the Tribunal’s dispositive reasoning.