Consult Solutions v Revenue & Customs [2011] UKFTT 429 (TC) (30 June 2011)

Consult Solutions v Revenue & Customs [2011] UKFTT 429 (TC) (30 June 2011)

The appellant acted as a prudent employer, exercised reasonable foresight and due diligence, and the failure to file was due to a systems or internet error beyond its control. The lack of knowledge regarding the receipt arrangement was understandable given it was the first year of mandatory online filing. Therefore, a reasonable excuse was established.

Citation
[2011] UKFTT 429
Parties
Appellant: Consult Solutions; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
30 June 2011
Procedural Posture
Tax Penalty Appeal / First Tier Tribunal Decision
Outcome
Appeal allowed
Legal Topics
Income Tax, Corporation Tax, PAYE, Penalty for Late Filing, Reasonable Excuse

Case Brief

Summary, issues, holding and outcome

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Parties

Consult Solutions

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Penalty Appeal / First Tier Tribunal Decision

  1. 1 Whether the appellant had a reasonable excuse for late filing of the employer’s annual return (P35)

Ratio Decidendi

The appellant acted as a prudent employer, exercised reasonable foresight and due diligence, and the failure to file was due to a systems or internet error beyond its control. The lack of knowledge regarding the receipt arrangement was understandable given it was the first year of mandatory online filing. Therefore, a reasonable excuse was established.

Court Disposition

Appeal allowed

Orders

  • Penalty of ₤400 discharged
  • HMRC not pursuing additional penalty of ₤100 for the period 20 September 2010 to 19 October 2010