.png)
.png)
Goldenstate Ltd (TC6012)
Application to change ground of appeal
The taxpayer had participated in a tax avoidance scheme. HMRC issued an accelerated payment notice (APN) under FA 2014 s 219(4)(b). The taxpayer made written representations against the notice but HMRC confirmed the sum due. The taxpayer paid it late so HMRC imposed a penalty for late payment.
The taxpayer appealed against the penalty. At first it claimed reasonable excuse but it later sought to amend its ground of appeal to challenge the validity of the APN. It said that HMRC’s enquiry into its return had been out of time. As a result condition A in s 219(2)(a) was not satisfied because there was no open enquiry.
The First-tier Tribunal refused the application. The judge said there was no good reason for the taxpayer...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
