New trustee is liable

The taxpayer company which had recently been incorporated was appointed trustee of an approved pension scheme in 2002.

In 2000 HMRC had tried to withdraw approval for the pension scheme with effect from 1996. The department wrote to the then trustees Louvre Trust Co and TM Trustees Ltd advising them approval was being withdrawn under TA 1988 s 591B.

Subsequently   the Revenue issued an assessment for £475 000 on Louvre Trust as trustee and a further assessment in January 2007 against the taxpayer company and TM Trustees.

The taxpayer company appealed. It claimed the withdrawal was ineffective because the taxman had addressed the notice incorrectly.

The tribunal ruled that although the Revenue had got the name of the trustee wrong there had been no confusion because both trustees were aware of the notice. It did...