TC09600 - [2025] UKFTT 00919 (TC)

Fecha: 03-Jul-2025

The length of the delays

The length of the delays

101.

The 2014-15 closure notice and the 2015-16 discovery assessment were both issued on 2 March 2020. Appeals should have been made within 30 days, so by 1 April 2020. Haines Watts asked to make late appeals against those two decisions in their letter of 10 September 2020, which was over five months late. That application was refused by HMRC on 19 May 2021. Ms Rahman applied to the Tribunal on Mr Milhill’s behalf almost three years later, on 2 February 2024.

102.

No appeal (or application for a late appeal) was made in relation to any of the other HMRC decisions until 2 February 2024. The length of delay therefore varies. The earliest in time is the late filing penalty for 2014-15 issued in February 2016 where the delay was almost eight years. The most recent were the late filing penalties issued on 15 August 2023 for £1,200, where the delay was 4.5 months.

103.

In relation to the decisions on which Ms Rahman focused her submissions:

(1)

the Sch 24 penalties were issued on 18 June 2021 and 17 September 2021, so the delay in both cases was over two years, and

(2)

the closure notices for 2016-17 through to 2018-19 were issued on 21 June 2021, so the delay was again well over two years.