In D Hill and another v HMRC [2024] UKFTT 844 (TC) (16 September) the FTT held that reliance on an adviser was not a reasonable excuse for failing to comply with an information notice and penalties were upheld without mitigation. The FTT decided that neither of the appellants took objectively appropriate steps to consider whether it was reasonable to rely on the advisers and the advice provided.
Mr Hill and Mr McCracken were scheme administrators for two pension schemes which were operated on their behalf by Liddell Dunbar Ltd a firm which later went into liquidation.
In January 2018 HMRC issued information notices to Mr Hill and Mr McCracken as scheme administrators. The firm advising the scheme administrators Independent Tax (IT) informed them that as the pension scheme had been wound up there ‘should be no need to respond’ to the...