TC09668 - [2025] UKFTT 01255 (TC)

The burden of establishing that they have issued and served on the appellant valid in time Notices of the penalty points and penalties for late submission, rests with HMRC. The standard of proof is the balance of probabilities or “more likely than not”.

The burden of establishing that the appellant had a reasonable excuse or that it should benefit from a special reduction because of special circumstances lies with the appellant. The appellant must establish these on the balance of probabilities.