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PLN Issue
PLN Issue
Legal test
Pursuant to paragraph 19(1) Sch 24 FA07 where a penalty is payable by a company for a deliberate inaccuracy, which was attributable to an officer of the company, the officer is liable to pay such proportion of the penalty as HMRC specify in a notice.
HMRC must therefore be satisfied that the deliberate conduct was so attributable.
Parties submissions
MJ and MB repeat that any deliberate conduct on the part of 3KH should not be attributed to them. HMRC repeated their submissions on deliberate conduct generally.
- Heading
- Introduction
- Brief factual and procedural background
- Burden of Proof
- Evidence
- Parties submission
- Findings of fact
- Evidence
- Parties submissions
- Findings of fact
- Best Judgement Issue
- Evidence
- Parties submissions
- Findings of fact
- VAT Quantum Issue
- Parties submissions
- Evidence
- Input Tax Issue
- Discussion
- Works on premises in Leicester
- 7 Wilmslow Road
- Vehicle hire invoices
- Birmingham Hotels invoices
- Discovery Issue
- Findings of fact
- Deliberate issue
- Parties submissions
- Findings of fact
- Participation Issue
- PLN Issue
- Findings of Fact
- Mitigation Issue
- Parties submissions
- Findings of fact
- Conclusions