Proving hardship in landfill tax appeals: practical tips for success

If you’re challenging a Landfill Tax (LFT) assessment, submitting a hardship application is an important first step. However, it’s the evidence you provide to support your claim of hardship that will determine whether your application is successful.

A successful hardship application does not cancel the tax itself; it simply allows your appeal to be heard without requiring you to pay the Landfill Tax upfront.

HM Revenue and Customs’s (HMRC) internal guidance (ARTG3340) sets out what officers expect to see and we want to highlight the core aspects that should inform your approach to the matter.

Understand the burden of proof

HMRC places the burden of proof squarely on the taxpayer.

There is no statutory list of required documents, but failure to provide sufficient evidence will almost certainly result in rejection.

The hardship officer must be able to form a complete and current picture of your financial position.

Provide recent and relevant financial documents

HMRC expects the following, where applicable:

  • Full annual accounts (including directors’ reports and detailed profit and loss)
  • Monthly management accounts up to the date of the request
  • Cash flow forecasts for at least the next 12 months
  • Up-to-date bank statements for all business and personal accounts
  • Loan and overdraft facility letters, including terms and limits
  • Details of assets such as property, shares, and insurance policies
  • Information on liabilities, including directors’ loans and related party balances

Explain gaps or missing information

If certain documents are unavailable, you will need to explain why.

This includes if you don’t prepare management accounts, provide a trial balance or produce extracts from your accounting system.

Transparency helps build credibility so be sure to evidence as much as you possibly can.

Address group support and related parties

If your business is part of a group, HMRC will expect you to explain whether group support is available.

If not, you must justify why assistance from related entities is not possible.

Demonstrate attempts to raise funds

If you’ve tried to borrow money to pay the tax, include evidence of loan applications and responses.

This shows you’ve explored all reasonable options before claiming hardship.

Highlight the consequences of payment

Make clear what would happen if you were forced to pay the tax now.

Would it:

  • Trigger insolvency?
  • Lead to redundancies?
  • Disrupt essential operations?

These consequences help HMRC assess the real-world impact of payment.

Keep it organised and professional

Present your evidence in a clear, indexed bundle.

Include a covering letter summarising your financial position and referencing the enclosed documents.

This helps the hardship officer navigate your case efficiently.

Be prepared for tribunal scrutiny

If HMRC refuses your application, the Tribunal can still grant hardship relief.

They will apply a value judgment based on the evidence you provide.

Verbal assertions alone carry little weight so written evidence is vital for success.

Preparation is everything

A well-evidenced hardship application can be the difference between having your appeal heard or being shut out of the process.

By following HMRC’s expectations and presenting a clear, honest picture of your financial position, you significantly improve your chances of success.

Our specialist team can support you with compliance awareness so that you do not get caught out. Contact John Dyne today for help.