In August the First-tier Tribunal (FTT) heard the first case involving a senior accounting officer (SAO) main duty penalty assessment in Thathiah v HMRC [2017] UKFTT 601 (TC). The SAO was assessed for main duty penalties for two consecutive years by HMRC after it came to light that the company had not applied its partial exemption special method (PESM) correctly resulting in errors in its VAT calculations. See figure 1 below for details of the SAO’s main duty.
The SAO appealed this assessment and the tribunal decision provides invaluable insight into what reasonable steps comprise and how this should be specifically considered in the light of the size and nature of the business. However certain...
