Digital Buying Partners Ltd v The Commissioners for HM Revenue and Customs [2024] UKUT 00437 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Jeanette Zaman on 23 December 2024
Read full decision
- The applicant, Digital Buying Partners Limited (“DBP”), applied to the Upper Tribunal (Tax and Chancery Chamber) for permission to appeal against the decision (the “Decision”) of the First-tier Tribunal (Tax Chamber) (“FTT”) released on 9 May 2024 (TC/2021/19787). DBP applied to the FTT for permission to appeal against the Decision on five grounds. In a decision notice released on 25 July 2024, the FTT refused permission on all grounds.
- On 17 August 2024 DBP renewed its application for permission to appeal for all five grounds, within the applicable time limit (the “Application”). I refused permission in a decision released on 16 October 2024 (the “Papers Refusal”).
- On 30 October 2024 DBP made an in-time application for that decision to be reconsidered at a hearing (the “Renewal Application”). The hearing (the “Renewal Hearing”) was held on 12 December 2024.