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Corporate Negligence

Craig Thomson of Deloitte's Tax Risk and Resolution Group discusses the Inland Revenue's approach to penalties for incorrect company tax returns

 
Craig Thomson of Deloitte's Tax Risk and Resolution Group discusses the Inland Revenue's approach to penalties for incorrect company tax returns
 
It is well known that bad cases can make for bad exposition of the law. Consider the following caricature of a penalty case before the Commissioners.
 
An unrepresented Arthur-Daley-type figure disputes the inspector's assertion that a penalty arises in view of tax returns having been submitted 'negligently'. The Revenue proceeds to evidence the taxpayer's unconventional approach to record-keeping backwardness in coming forward and perhaps the existence of one bank account too many. The Commissioners not surprisingly deal with the matter shortly in favour of the Revenue.

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