Figa Store Limited v The Commissioners for HMRC

Decision date: 23 October 2025

Neutral citation: [2025] UKFTT 1260 (TC)

Overall AI summary confidence: high

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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

Figa Store applied for permission to bring a 17‑day-late appeal against a C18 demand; the Tribunal found the short delay not serious, accepted the appellant’s explanations, and allowed the late appeal. The Tribunal also held that omission of documents referred to in FTT Rule 20(3) did not automatically make the NOA invalid and would, in any event, exercise its discretion under Rule 7 to remedy or waive that single defect so the appeal could proceed.

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 Tribunal’s operative ratio is that where a notice of appeal is filed within the statutory time limit but omits documents required by FTT Rule 20(3), the appeal is not necessarily late or invalid; the FTT has discretion under Rule 7 to remedy or waive failures to comply with Rules 20(2)/(3) and may admit the appeal and require the defect to be remedied rather than rejecting it. The Tribunal also applied the usual three‑stage test for extensions and treated a 17‑day delay as not serious in the circumstances.

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 contains obiter remarks that the interpretation of Rule 20 should be guided by the overriding objective to deal with cases fairly and justly, and that automatically rejecting an NOA solely because of missing Rule 20(3) documents would be inconsistent with the Rules’ flexibility; Rule 7 supports a remedial, rather than rigid, approach.

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