No chance appeal would succeed

The taxpayer applied to the First-tier Tribunal for permission to make a late appeal against an assessment raised in July 2016. He notified the appeal in March 2020.

The assessment was for an unauthorised payment charge and surcharge in respect of a transfer to an overseas pension. The taxpayer who was resident in South Africa transferred funds from his UK pension to an overseas scheme which he believed was a qualified recognised overseas pension scheme (QROPS). As such the transfer would not been subject to tax. However shortly before he made the transfer HMRC removed the scheme from the QROPS list as a result of which the transfer incurred an unauthorised payment charge under FA 2004 s 208 and a 15% unauthorised payment surcharge under s 209.

After he received the assessment he contacted HMRC to ask how to appeal but seemed...