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Special reduction
Special reduction
In light of our finding on reasonable excuse, we did not need to consider special reduction. However, we told the parties at the end of the hearing that, had we not accepted the Appellant’s case on the basis of reasonable excuse, we would have concluded that this was a case where we would have reduced the penalty to nil by reason of special reduction. Our reasons are as follows.
- Heading
- Introduction
- Overview of the case
- The legislative scheme
- The case law on reasonable excuse
- The case law on special reduction
- Findings of fact
- The Appellant’s complaint to HMRC
- Penalty for late payment
- Reasonable excuse
- Discussion
- Special reduction
- HMRC’s arguments
- The Appellant’s arguments
- Discussion
- Conclusions