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HMRC’s dropped appeal against the First-tier Tribunal

Lindsey Wicks, technical editor in the Tax Faculty, considers the implications of HMRC dropping its appeal against a First-tier Tribunal win for the taxpayer in the Hymanson case concerning lifetime allowance fixed protection.

The First-tier Tribunal (FTT) released its decision in Hymanson [2018] UKFTT 667 (TC) on 13 November 2018, allowing a taxpayer’s appeal against HMRC’s decision to revoke his certificate of fixed protection. HMRC had originally applied to appeal this decision to the Upper Tribunal (UT). However, the updated appeals listings on 24 May 2019 showed that HMRC’s appeal had been withdrawn.

Does this open the floodgates for other taxpayers in a similar position, or was this a tactical move by HMRC?