The Commissioners for HM Revenue and Customs v Marc Gunnarsson [2025] UKUT 00247 (TCC)

Upper Tribunal Tax and Chancery decision of Judge Jones and Judge Tilakapala on 23 July 2025

Read full decision: The Commissioners for HM Revenue and Customs v Marc Gunnarsson

INCOME TAX –– FTT erred in deciding Respondent was entitled to coronavirus support payments pursuant to the Self-Employment Income Support Scheme “SEISS” – Respondent was not a qualifying person at the relevant time because he was not self-employed but a director or employee of a limited company which was trading - HMRC’s appeal allowed – FTT Decision set aside and remade confirming HMRC’s assessment to recover the payments.

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Published 24 July 2025