PENALTY

The Court of Appeal’s reasoning in Sintra Global misses key principles and authorities, writes Michael Firth KC (Gray’s Inn Tax Chambers).

Residency dispute and appeal against self-assessment penalties 

Court of Appeal considers burden of proof in penalty appeals 

Costs awarded because of taxpayer’s unreasonable conduct: In HMRC v Mattu [2025] UKUT 410 (TCC) (16 December 2021), the UT awarded HMRC £5,000 in costs under rule 10(3)(d) of the UT rules (SI 2008/2698), confirming that there is no requirement for a...

FTT imposes penalty on promoter of notifiable annuity-based umbrella arrangements.

Upper Tribunal follows Medpro when applying Martland three-stage test, but still refuses late appeal application 

VAT exemption for private tuition: Rushby Dance and Fitness centre and others v HMRC [2025] UKFTT 594 (TC) (29 May) is part of a group of four related cases concerning the VAT exemption for private tuition. The exemption applies to the supply of...

FTT imposes maximum £1m DOTAS penalty for failure to notify  

ADR exit agreement was binding and enforceable.