Minimal penalty brings later years into charge

The taxpayer was an employee whose base salary was below £50 000 a year but whose overtime and weekend working took him over that in the years 2013-14 2015-16 and 2016-17. As a result he unknowingly became liable to the high income child benefit charge. He did not notify his liability to HMRC (TMA 1970 s 7). The ordinary time limit of four years after the year of assessment (s 34) did not apply here because it was a failure to comply with an obligation under s 7. Section 36(1A)(b) therefore applies giving HMRC up to 20 years to collect the tax. It raised assessments and imposed penalties.

The taxpayer accepted the charge was due and paid it. He appealed against the penalties. His main ground was that HMRC had not told him about the charge.

The First-tier Tribunal was satisfied that HMRC had made the public...