TC09493 - [2025] UKFTT 00456 (TC)

This appeal concerns the High Income Child Benefit Charge (“HICBC” or “the charge”). The appellant had originally been assessed (“the assessments”) to HICBC for the tax years 2015/2016 to 2019/2020 together with penalties (“thepenalties”) for failing to notify chargeability under section 7 Taxes Management Act 1970 (“TMA”). The assessments amounted in total to £5,401. The penalty assessments were for £972.60.

The assessments were issued on 17 May 2022. In October 2024 HMRC appeared to accept that the appellant’s behaviour as regards the charge was not careless and that he had a reasonable excuse for the penalties. Accordingly, they accepted that the four year limitation period for issuing a discovery assessment applied with the consequence that the only assessments which were under appeal were those in respect of the tax years 2018/2019 and 2019/2020 (“the two relevant tax years”). The charges in each of those years is £1,076.

Furthermore, HMRC no longer asserted that the penalties were due.

So, the hearing was much simplified, and we were required only to decide whether the assessments for the two relevant tax years were valid in time assessments, and if they were, whether the appellant could establish that they overcharged him.

For the reasons given below, we have found that the assessments for those years were valid in time discovery assessments, and did not overcharge the appellant. We have therefore dismissed the appeal against the assessments for those two years. If formally required, we uphold his appeal against assessments for the preceding three years, and against the penalties.