The case first went to the First Tier Tribunal (FTT) in 2022 but the Premier League club has now had its appeal rejected at the Upper Tribunal on three grounds.

HMRC issued the initial assessment to Nottingham Forest on 29 April 2019 relating to VAT for the quarter ending 08/15. However, the Club argued that HMRC had breached its one-year time limit for VAT assessments under section 73(6)(b) of VAT Act 1994.

It was up to Nottingham Forest to prove this, a case which it lost at the FTT in 2022 and was later granted permission to appeal to the Upper Tribunal.

The Club did attempt to correct the mistake at the time, submitting an error correction notice in November 2015 for £126,984.

On 24 May 2018, HMRC notified the Club that it may have under-declared its output tax by £88,125, and over-declared its input tax by £258,409, a total of £346,534. The total figure was later increased to £348,177.

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