TC09681 - [2025] UKFTT 01333 (TC)

Case Number: TC09681

Location: Decided on the papers

Appeal reference: TC/2023/00598

INCOME TAX – NATIONAL INSURANCE CONTRIBUTIONS – HMRC’s application for penalties under Section 98C(1)(a) and (2)(a) Taxes Management Act 1970 – whether Respondent company promoter of notifiable arrangements – whether failure to comply with obligations – whether reasonable excuse for failure – calculation of penalties

Judgment date: 10 November 2025

Decided by:

TRIBUNAL JUDGE BAILEY

Between

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Applicants

and

MOIR MANAGEMENT SERVICES LIMITED

Respondent

The Tribunal determined the application on 30 and 31 July 2025 without a hearing under the provisions of Rule 29 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 having first read the Notice of Application dated 12 January 2023, with bundle of documents in support, the Applicants’ written submissions and authorities bundle, both filed on 10 June 2025, and the documents on the Tribunal file including, in particular, the Respondent’s letter of 25 March 2025 (with enclosures).

DECISION