TC09681 - [2025] UKFTT 01333 (TC)

I have decided as follows in respect of the four issues before the FTT:

I have decided that Moir was a “promoter” of “notifiable arrangements” as defined by sections 306 and 307 Finance Act 2004 (“FA 2004”).

I have decided that Moir did fail to comply with its obligations under sections 308 and 313A FA 2004.

I have decided that Moir does not have a reasonable excuse for its non-compliance.

I have decided that the total penalties to be imposed on Moir are £1,596,800.

This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.