No infringement of human rights

The taxpayer made a late appeal against a personal liability notice (PLN). HMRC had imposed a penalty on Kronstadt Constructors of which the taxpayer was a director because of a deliberate inaccuracy in its VAT return.

The only issue of this appeal was whether to admit the late appeal.

The taxpayer claimed that he was not notified of the PLN so his time for appealing has not started to run. Further he said because he does not understand English the notice had to be notified in a form that complied with article 6(3)(a) of the European Convention on Human Rights.

The First-tier Tribunal noted that HMRC was ‘sceptical’ of the taxpayer’s claim not to understand English and it could understand why. He had lived in the UK for several years and run a business he was able to speak other languages fluently –...