Bowland Inns and Hotels Limited v The Commissioners for HMRC

Facts

Bowland Inns and Hotels Limited operates hotels and inns in the Northwest of England and offers wedding packages comprising a ceremony room, wedding breakfast, evening reception and overnight accommodation, each component separately priced. In its 08/21 and 11/21 VAT accounting periods it accounted for VAT on food and overnight accommodation within those packages at the temporary reduced rate under Groups 14 and 15 of Schedule 7A to the Value Added Tax Act 1994, having done so in its 05/21 period too. HMRC assessed the 05/21 period on 30 May 2025 (later reduced to £48,019 on review) on the basis that the packages were single composite supplies; Bowland appealed that assessment in time. On 18 August 2025 HMRC issued a further assessment of £463,988 for the 08/21 and 11/21 periods on the same basis. A review was offered but not accepted, and Bowland, having discovered that no appeal had been made in time, appealed on 28 January 2026 and included an application for permission to appeal out of time in its Notice of Appeal. HMRC opposed the application. The appeal was 134 days late, the delay being attributed to an administrative error by Bowland's representatives, KPMG LLP. The application was determined on the papers by Tribunal Judge Brooks in the First-tier Tribunal (Tax Chamber).