TC09512 - [2025] UKFTT 00522 (TC)

Fecha: 11-Abr-2025

Introduction

Introduction

These appeals concern discovery assessments (issued by HM Revenue & Customs (HMRC) pursuant to section 29 Taxes Management Act 1970 (TMA)) and penalties (issued pursuant to Schedule 24 Finance Act 2007) following disclosures made by Mr Shamsul Arefin (SA) and Mrs Nazmun Nahar (NN) (together Appellants) under the contract disclosure facility (CDF).

HMRC issued the following discovery assessments on 4 February 2020 (Assessments) and penalties on 3 November 2020 (Penalties). The quantum of the Assessments (and correspondingly the Penalties) were reduced following HMRC’s review. In March 2025 the parties engaged in an alternative dispute resolution process. Whilst the process was unsuccessful in resolving the dispute in full certain further concessions were made by HMRC. HMRC invited us to uphold the Assessments and Penalties in the following amounts:

Tax yr ended	SA Assessment	SA Penalty	NN Assessment	NN Penalty
05/04/2010	11,113.10	7,362.43	7155.00	0
05/04/2011	17,068.78	10,027.91	11,979.00	7,037.66
05/04/2012	19,988.38	11,922.17	20,530.00	12,240.37
05/04/2013	25,681.66	15,315.78	22,621.42	13,517.89
05/04/2014	31,917.55	18,979.37	25,569.31	15,249.78
05/04/2015	15,634.88	9413.30	11,471.00	6967.02
Total	121,404.35	73,020.95	99,285.73	55,012.45