PENALTIES

The January Barclays tech outage shines a light on the sometimes uncompromising interest and penalty regimes facing taxpayers which, in this context, demand flexibility, write Jessica Kemp and Catherine Hill (White & Case).

Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February), the taxpayer was given limited permission to appeal to the UT against closure notices, assessments and penalties. The decision of the UT in rejecting the...

Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...

Daniel Lusted

Daniel Lusted (BDO) examines what’s being proposed.

SDLT MDR was available:T Yeomans v HMRC [2024] UKFTT 955 (TC) (24 October) is another SDLT multiple dwellings relief case but unlike some other cases, where the phrase ‘clutching at straws’ comes to mind, this one was clearly...

Sophie Rhind

Victoria Braid

Mainpay should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).

Damiano Sogaro

Edward Reed

Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.

Penalties for incorrect BADR claim upheld.

Procedure for assessing penalties:I Majid v HMRC [2024] UKFTT 491 (TC) (25 May) is what might be seen as a routine appeal against a penalty determination, but there is one point of general interest. An officer of HMRC had spoken to the...

Matthew Greene

Following a recent case, we can probably expect HMRC to be less flexible on taxpayer requests for more time to comply with information notices, writes Matthew Greene (Stewarts).

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