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Late filed land transaction return

The taxpayer appealed against a penalty imposed by HMRC for the late submission of a land transaction return. It said it had done everything reasonable to file on time but was unable to do so because HMRC had failed to issue a VAT number or unique taxpayer reference (UTR). Although the guidance stated that a company registration number (CRN) could be used the taxpayer believed it was reasonable to assume that as a limited liability partnership (LLP) it would not have one.

The First-tier Tribunal judge referred to the HMRC guidance for submitting a return and noted that it said to call the helpline if the taxpayer did not have any unique references. This is what the taxpayer did. But this was not helpful. The judge said: ‘The helpline did not seem to have appreciated the difference between a Companies Act company...