The appellant company was not entitled to CJRS payments as the relevant conditions were found not to have been satisfied, including that the company’s sole director had worked throughout lockdown. 

The appellant company (SWG) had a sole director shareholder (SG). SWG provided services repairing and maintaining injection moulding machines, either in person via visits to the clients’ premises, or remotely online. SWG’s operations continued normally until the Coronavirus lockdown was announced on 23 March 2020. The business then came to a standstill for a few days, after which SG began taking calls from customers and providing help and advice remotely. He admitted to HM Revenue and Customs (HMRC) that he worked for around 18 hours between the beginning of lockdown and 30 April 2020. 

Following a compliance check into SWG’s Coronavirus job retention scheme (CJRS) claims, HMRC issued assessments to recover amounts