Late appeal against scheme reference number

HMRC wrote to the taxpayer to say it might allocate a scheme reference number (SRN) to specified arrangements. The letter explained that HMRC suspected the taxpayer might be a promoter of the arrangements and if it disagreed that they were notifiable it should inform HMRC by a given date.

The taxpayer did not reply to the letter by that date so HMRC allocated a scheme reference number and told the taxpayer what action it should take.

The taxpayer subsequently appointed an adviser who emailed HMRC to ask that the SRN be withdrawn and that before publishing any information HMRC should consider the taxpayer’s response to HMRC’s initial letter. The taxpayer went on to make representations about the publication of its details and appealed against the SRN.

However HMRC did publish the taxpayer’s details on its website in the ‘current list of names tax avoidance schemes ...