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Another case that caught our eye: 14 February 2025

Reasonable excuse and reliance on third party: In Xcel Consult Ltd v HMRC [2025] UKFTT 96 (TC) (30 January) the taxpayer was arguing that she had a reasonable excuse defence in her appeal against a VAT surcharge because she had relied on her accountant who had let her down. The FTT noted that HMRC’s guidance on reasonable excuse (at www.gov.uk/tax-appeals/reasonable-excuses) said: ‘a reasonable excuse is something that stopped you meeting a tax obligation for a valid reason for example ... you relied on somebody else to send your return and they did not’. The taxpayer argued that that meant that she had a reasonable excuse. The FTT disagreed saying that looked at in context and when the relevant links were followed the guidance did not mean that reliance on a third party should be treated as a reasonable excuse only that in...

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