HMRC had paused the assessments

The taxpayer was an employee subject to PAYE and was not required to complete self assessment tax returns. Her first child was born in 2007 and she claimed child benefit.

HMRC wrote to her in the tax year 2013-14 when her income first exceeded £50 000. It did not send her the SA252 letter about the introduction of the high income child benefit charge (HICBC). In 2019 HMRC sent the taxpayer ‘educational’ letters about the charge. However she did not receive them because she had moved in 2016 and although she had notified HMRC it had not updated its records.

The First-tier Tribunal accepted that because the taxpayer was not a higher rate taxpayer in 2012-13 it was ‘unlikely’ she would have paid any attention to the campaigns to raise awareness about the charge in 2012 and 2013.

On 10 May 2021 HMRC wrote...