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Smith v Revenue and Customs (INCOME TAX and VAT) [2026] UKFTT 663 (TC) (06 May 2026)
The Tribunal upheld HMRC’s income tax and VAT assessments and most penalties, finding the appellant continued to run the business after March 2003, but ordered recalculation where figures overcharged.
Revenue and Customs v WS Vision Ltd (INCOME TAX - NATIONAL INSURANCE CONTRIBUTIONS) [2025] UKFTT 1535 (TC) (09 December 2025)
The Tribunal held WS Vision Ltd was a promoter of notifiable DOTAS arrangements, failed to disclose them, had no reasonable excuse, and was penalised £1 million.
Revenue and Customs v WS Vision Ltd (INCOME TAX - NATIONAL INSURANCE CONTRIBUTIONS) [2025] UKFTT 1535 (TC) (09 December 2025)
The FTT held WS Vision Ltd was a promoter of notifiable tax arrangements, failed to disclose them under DOTAS, had no reasonable excuse, and was fined £1 million.
Schwarze v Revenue and Customs (Application for permission to make a late appeal to HMRC - Schedule 36 Finance Act 2008 penalties - Schedule 24 Finance Act 2007 penalties - whether notification given - s115 Taxes Management Act 1970 - notification not given re Schedule 24 Finance Act 2007 penalties - three stage approach in Martland applied - Medpro approach to weight to be given to 'compliance' factors taken stricter Martland approach undertaken as a cross-check) [2026] UKFTT 28 (TC) (13 November 2025)
The tribunal refused a late appeal over Schedule 36 penalties, but held the Schedule 24 penalties were not properly notified and were therefore not out of time.
Arefin & Anor v Revenue and Customs (INCOME TAX - discovery assessments following contract disclosure facility report - dispute as to quantum - appeal allowed in part) [2025] UKFTT 522 (TC) (08 May 2025)
The tribunal partly allowed appeals against discovery assessments and penalties, reducing some 2009/10 and property-income figures but refusing any further penalty mitigation.
Atkinson v Revenue and Customs (LATE APPEAL - Martland test applied - length of delay was serious and significant) [2025] UKFTT 414 (TC) (07 April 2025)
The tribunal refused permission for a late tax appeal, applying Martland and finding the delays were serious and significant, with no good reason for years of delay.
Thompson v Revenue and Customs [2025] UKFTT 272 (TC) (27 February 2025)
The First-tier Tribunal refused Mr Thompson’s appeal against Schedule 24 penalties, finding his inaccurate tax returns were deliberate and that HMRC had proved its case.
Moore v Revenue and Customs (INCOME TAX - Follower Notice - penalty) [2024] UKFTT 518 (TC) (13 June 2024)
The Tribunal dismissed Mr Moore’s appeal against follower notice penalties, finding he failed to take corrective action in time and had no reasonable excuse.
IPS PROGRESSION LIMITED v Revenue & Customs (DISCLOSURE OF TAX AVOIDANCE SCHEMES (DOTAS) [2024] UKFTT 136 (TC) (12 February 2024)
The Tribunal held that IPS Progression Limited operated notifiable DOTAS arrangements, was a promoter, failed to disclose in time, and was fined £900,000.
DELPHI DERIVATIVES LIMITED v Revenue & Customs (PENALTY - Schedule 24 Finance Act 2007 - Employee Benefit Trust ('EBT') Clavis Scheme whereby EBT contributions made via a service provider) [2023] UKFTT 722 (TC) (18 August 2023)
The Tribunal upheld a Schedule 24 penalty against Delphi Derivatives Limited over EBT-related return inaccuracies, finding the scheme ineffective and the errors at least careless.
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