HM Revenue & Customs (appellant) v Medpro Healthcare Ltd & ors (respondents)

Wednesday 17 December 2025

By appellant’s notice filed on 13 November 2025, HMRC appeals a decision of the Upper Tribunal (Tax and Chancery Chamber) released on 30 July 2025 which allowed the Respondents’ appeal against a decision of the First Tier Tribunal on various grounds.

The appeal concerns the extent to which the Upper Tribunal (Tax & Chancery Chamber) can give guidance to the First-tier Tribunal (Tax Chamber) (“FTT”) on how its statutory discretion should be exercised on applications to make appeals to it beyond the permitted statutory time limits. Whilst this appeal immediately concerns VAT, its effect extends to any appeals made to the FTT where there is a statutory discretion to permit a late appeal that does not state therein either any particular factors to be taken into account, or the weight to be given to any such factors.

View hearing:

Part 1

Part 2