Kamperis v Revenue and Customs (INCOME TAX - participation in Montpelier Scheme - exploitation of Double Taxation Agreement between the UK and the Isle of Man) [2025] UKFTT 1441 (TC) (24 November 2025)

Kamperis v Revenue and Customs (INCOME TAX - participation in Montpelier Scheme - exploitation of Double Taxation Agreement between the UK and the Isle of Man) [2025] UKFTT 1441 (TC) (24 November 2025)

The Tribunal held that the statutory requirements for issuing follower notice penalties were met, the appellant failed to take the required corrective action by the specified deadline, and his actions were not reasonable in all the circumstances. The appellant's payment of APNs did not constitute corrective action, and reliance on professional advice or HMRC's administrative conduct did not amount to a reasonable excuse. The penalties were properly calculated and no further reduction was warranted.

Citation
[2025] UKFTT 1441 (TC)
Parties
Appellant: Georgios Kamperis; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
24 November 2025
Procedural Posture
Income Tax Appeal (follower Notice Penalties) / First Tier Tribunal (tax) Final Judgment
Outcome
Appeal dismissed
Legal Topics
Income Tax, Tax Avoidance Schemes, Follower Notices, Double Taxation Agreements, Penalties, Corrective Action, Reasonable Excuse, HMRC Powers
Tax Law Income Tax Tax Avoidance Schemes Follower Notices Double Taxation Agreements Penalties Corrective Action Reasonable Excuse +1 more

Case Brief

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Parties

Georgios Kamperis

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal (follower Notice Penalties) / First Tier Tribunal (tax) Final Judgment

Legal Issues

  1. 1 Whether follower notice penalties were correctly issued under s 208 Finance Act 2014
  2. 2 Whether the appellant took corrective action by the specified time
  3. 3 Whether the appellant's actions were reasonable in all the circumstances

Ratio Decidendi

The Tribunal held that the statutory requirements for issuing follower notice penalties were met, the appellant failed to take the required corrective action by the specified deadline, and his actions were not reasonable in all the circumstances. The appellant's payment of APNs did not constitute corrective action, and reliance on professional advice or HMRC's administrative conduct did not amount to a reasonable excuse. The penalties were properly calculated and no further reduction was warranted.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.
  • The follower notice penalties in the sum of £39,153.22 are upheld.