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England and Wales decisions
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Liquidators’ claims against two doctors failed: no proven employment contracts and no transaction at an undervalue where the payments had already been accounted for to HMRC.
The Tribunal found that the Appellant was the sole shareholder during the relevant tax years, as evidenced by Companies House records and absence of contrary evidence. Therefore, all dividends were correctly assessed on him. The Discovery Assessment and Closure Notices were valid, competent, and in time. The Appellant failed to discharge the burden of proof to show the assessments were excessive or incorrect. The omissions of dividend income, benefit in kind, and HICBC were due to careless or deliberate behaviour. The penalty was validly imposed. The appeals were dismissed and assessments inc…
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Given the significant and serious delay, lack of credible explanation, and clear notification of appeal rights, permission for late appeals is refused.
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The appellant was legally required to file a 2020/21 SATR as the section 8 notice was properly served; ignorance of the requirement and failure to make arrangements for post and tax affairs while abroad did not constitute a reasonable excuse; late filing penalties were properly assessed and served.
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The Tribunal found that Mrs Awan did not have a reasonable excuse for the late filing as she had agreed to electronic communications and failed to check her online account. The penalties were correctly issued and proportionate, and there were no special circumstances warranting reduction.
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The Tribunal dismissed an appeal against closure notices amending self-assessment returns, finding HMRC used best judgment and the appellant failed to disprove the figures.
The Court of Appeal held that an SDLT repayment claim under section 44(9) FA 2003 had to be made within the 12-month amendment period and was out of time.
The Tribunal dismissed Mr Breen’s appeal against a late-filing penalty, finding no reasonable excuse and no special circumstances to reduce the Schedule 55 penalty.
Revenue And Customs v Sanders [2021] EWHC 1843 (Ch) (07 July 2021)
The High Court allowed HMRC’s application, holding that its closure notice and accompanying explanation validly supported HMRC’s proof of debt in the deceased’s insolvent estate.
The High Court held that HMRC validly amended partnership loss claims and could recover overpaid tax and earlier-year repayments under section 59B(5) TMA.
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