Barlow v Revenue & Customs (for failure to take corrective action following service of Follower Notice) [2020] UKFTT 486 (TC) (30 November 2020)
It was not shown in all the circumstances that Mr Barlow acted reasonably in failing to take corrective action; however, the quality of his cooperation warrants a reduction of the penalty to 25% of the denied advantage.
- Citation
- [2020] UKFTT 486
- Parties
- Appellant: Raymond Barlow; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 30 November 2020
- Procedural Posture
- Appeal / Final Judgment
- Outcome
- Penalties upheld; reduction applied
- Legal Topics
- Follower Notice Penalties, Finance Act 2014, Corrective Action, Penalty Reduction, Cooperation With HMRC
Case Brief
Summary, issues, holding and outcome
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Parties
Raymond Barlow
Appellant
The Commissioners for Her Majesty’s Revenue & Customs
Respondents
Procedural Posture
Appeal / Final Judgment
Legal Issues
- 1 Whether it was reasonable in all the circumstances for the taxpayer not to have taken corrective action following service of Follower Notices
- 2 Whether the penalty reduction applied by HMRC was appropriate
Ratio Decidendi
It was not shown in all the circumstances that Mr Barlow acted reasonably in failing to take corrective action; however, the quality of his cooperation warrants a reduction of the penalty to 25% of the denied advantage.
Court Disposition
Penalties upheld; reduction applied
Orders
- Penalties reduced to 25% of the denied advantage for each relevant tax year
Full Case Text
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