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The fact that there was no tax liability in the years in which the tax returns were filed late, does not affect the validity of the penalties. This was made clear to the appellant in Judge Rankin’s de
The fact that there was no tax liability in the years in which the tax returns were filed late, does not affect the validity of the penalties. This was made clear to the appellant in Judge Rankin’s decision and stems from the Upper Tribunal’s decision in Edwards.
- Heading
- INTRODUCTION
- THE LEGISLATION
- Special circumstances
- Reasonable excuse
- Reasonable excuse
- Special Circumstances
- THE EVIDENCE AND THE FACTS
- The tax returns were filed very late
- The fact that there was no tax liability in the years in which the tax returns were filed late, does not affect the validity of the penalties. This was made clear to the appellant in Judge Rankin’s de
- Similarly, we have no power to discharge or adjust a fixed penalty simply because we consider it to be unfair (see Hok Ltd v HMRC [2012] UKUT 363 (“ Hok ”) Reliance on an agent cannot be a reasonable excuse by dint of paragraph 23(2)(b) Schedule 55
- HMRC have not established that valid notices to file were served on the appellant
- Our view
- Conclusion
- Conclusions