TC09493 - [2025] UKFTT 00456 (TC)

In light of our findings of fact regarding the validity of the discovery and the assessments for the two relevant tax years, and the acceptance by the appellant that in each of those years his ANI was, as asserted by HMRC, more than £60,000, we have no alternative other than to dismiss the appellant’s appeal against the assessments for the two relevant tax years.

What this means in financial terms is that the appellant is liable to the charge for those tax years in a total amount of £2,152. He may also be liable for interest on that amount. He has no liability to the charge for the other tax years, nor to penalties for any of the tax years which were originally assessed.

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.