HMRC loses £95k top slicing relief calculation dispute

Two taxpayers have won an appeal against HMRC’s denial of their claims for overpayment relief totaling £95,959.63

In Joye [2025] TC 09547, the First Tier Tribunal (FTT) allowed the appellants’ appeals against HMRC’s denial of their claims for overpayment relief, holding that HMRC had failed to discharge their burden of proving that the top slicing relief calculations in the appellants’ self assessment returns were made in accordance with the ‘practice generally prevailing’ at the time.

The pra

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