HMRC’s ‘mantra’ for the definition of reasonable excuse
The First-tier Tribunal has not taken a consistent approach in deciding whether or not there is a reasonable excuse for non-resident capital gains tax (NRCGT) being filed late.
Some tribunals appear more sympathetic than others.
When is an application to reduce penalties because of ‘special circumstances’ a better bet than ‘reasonable excuse’? Peter Vaines (Squire Patton Boggs) considers a recent tribunal decision.