Late claim permitted

The taxpayer was a retired corporate financier but had no expertise in the field of pensions or personal finance.

After taking financial advice he set up a self-invested personal pension (SIPP). At 6 April 2006. the value of the plan was more than £4.2m.

The taxpayer changed the trustee of his SIPP in 2010. The new trustee told him he should have applied for enhanced protection by 5 April 2009. The previous trustee had not done this so a late application was submitted to HMRC in September.

The Revenue refused to accept the late notification. The taxpayer appealed claiming he had reasonable excuse having relied on his financial adviser to make the claim by the deadline.

The First-tier Tribunal accepted that the taxpayer had reasonable excuse. He had asked his financial adviser about the new rules for SIPPs in 2004.

At a meeting in January 2006...