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Who dunnit?
Key points
- In some circumstances HMRC has the power to transfer the liability to pay a penalty from the company to one or more of its officers.
- There must be deliberate behaviour specifically attributable to actions of the said officers.
- The tribunal has examined the broad scope of what constitutes deliberate behaviour.
- Importance of the decision in Farrow and the ‘good faith’ principle in establishing the burden of proof.
HMRC’s penalty regime introduced in FA 2007 Sch 24 and FA 2008 Sch 41 has been the centre of much discussion since its inception. It has significantly enhanced HMRC powers and given the department a new weapon as part of its compliance toolbox. This is the ability to transfer the liability to pay a penalty from a company to its officers by issuing...
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