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Private client briefing for March 2018

Andrew Goldstone and Katie Doyle (Mishcon de Reya) review recent developments in the private client world.
 

Hills Residential: all reasonable steps taken to file return

Hills Residential Ltd and Latimer Developments Ltd v HMRC[2018] UKFTT 0039 was an appeal by Latimer Hill LLP against a penalty of £100 imposed by HMRC for the late-filing of a SDLT return following a £15 000 000 land acquisition. The FTT considered the steps the appellant had taken in applying for a VAT registration number and a unique taxpayer reference number. The SDLT return and payment of tax were due by 24 March 2017 but despite the taxpayer chasing on 2 March 8 March and 22 March 2017 neither the VAT number nor the UTR had been received by then. HMRC accepted the appellant’s contention that the lack of a VAT number was delaying payment of the tax due. The...

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