Armkor Ltd v Revenue & Customs [2014] UKFTT 140 (TC) (29 January 2014)

Armkor Ltd v Revenue & Customs [2014] UKFTT 140 (TC) (29 January 2014)

The Tribunal found that the illness and unexpected death of the administrator constituted a reasonable excuse for the 09/11 period, but by 03/12 the appellant should have implemented adequate procedures. The penalty for 03/12 was not disproportionate given the facts and the appellant's compliance history.

Citation
[2014] UKFTT 140 (TC)
Parties
Appellant: Armkor Ltd; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
29 January 2014
Procedural Posture
VAT Default Surcharge Appeal / First Tier Tribunal (tax Chamber) Decision
Outcome
Appeal allowed in part, dismissed in part.
Legal Topics
VAT Default Surcharge, Reasonable Excuse, Proportionality of Penalty

Case Brief

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Parties

Armkor Ltd

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

VAT Default Surcharge Appeal / First Tier Tribunal (tax Chamber) Decision

  1. 1 Whether the appellant had a reasonable excuse for late VAT payment for periods 09/11 and 03/12
  2. 2 Whether the penalty imposed was disproportionate

Ratio Decidendi

The Tribunal found that the illness and unexpected death of the administrator constituted a reasonable excuse for the 09/11 period, but by 03/12 the appellant should have implemented adequate procedures. The penalty for 03/12 was not disproportionate given the facts and the appellant's compliance history.

Court Disposition

Appeal allowed in part, dismissed in part.

Orders

  • Default surcharge penalty for 09/11 period removed.
  • Default surcharge penalty for 03/12 period upheld.