Other cases that caught our eye: 18 November 2022

Appealing penalties for deliberate or fraudulent behaviour: P Dowds v HMRC [2022] UKFTT 402 (TC) (3 November 2022) considers no particular technical difficulties but nonetheless has a few points of interest. Assessments for multiple years to income tax PAYE NICs and VAT together with associated penalties were under appeal following an investigation by HMRC under COP 9. The FTT had no difficulty in upholding both the assessments and penalties on the basis of deliberate or fraudulent behaviour. Two of the taxpayer’s grounds of appeal were however eye-catching. The first was that the inaccuracies in his returns resulted from his having acted as an informant to Customs and Excise at Belfast docks. Following his exposure he was forced to make protection payments and had to conceal his income in order to divert the hidden monies to meet the payments. The second ground was that he...