Suspension of surcharges—deferred payment agreement
In G & Mrs L Kofteros v HMRC (TC02692 – 20 May) a married couple appealed against surcharges relating to a substantial CGT liability contending that they had been seeking to raise funds by selling shares and had requested a deferred payment agreement. The First-tier Tribunal accepted their evidence and allowed their appeals. Sir Stephen Oliver found that HMRC had received the couple’s application but had failed to reach a decision and that the couple had ‘had reasonable grounds for expecting that a time to pay agreement would be reached’.
Why it matters: FA 2009 s 108 provides for the suspension of surcharges where there is a deferred payment agreement. The First-tier Tribunal held that since HMRC had failed to respond to the appellants’ application for such an agreement they had a reasonable excuse for...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Suspension of surcharges—deferred payment agreement
In G & Mrs L Kofteros v HMRC (TC02692 – 20 May) a married couple appealed against surcharges relating to a substantial CGT liability contending that they had been seeking to raise funds by selling shares and had requested a deferred payment agreement. The First-tier Tribunal accepted their evidence and allowed their appeals. Sir Stephen Oliver found that HMRC had received the couple’s application but had failed to reach a decision and that the couple had ‘had reasonable grounds for expecting that a time to pay agreement would be reached’.
Why it matters: FA 2009 s 108 provides for the suspension of surcharges where there is a deferred payment agreement. The First-tier Tribunal held that since HMRC had failed to respond to the appellants’ application for such an agreement they had a reasonable excuse for...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: