Q&A: Hill v HMRC

In Hill and Another v HMRC [2024] UKFTT 00844 (TC) the First-tier Tribunal (FTT) found that reliance on an adviser was not a reasonable excuse for not complying with information notices and upheld HMRC’s penalties in full.

Even though the taxpayers did not understand the technical arguments it was found on the facts that they should have done more to question the advice that was given to them. As a result of this deficiency the FTT concluded that they had not taken reasonable care in relying on the advice they had received.

What are the facts of the case?

Mr Hill and Mr McCracken (the appellants) were scheme administrators of pension schemes. Liddell Dunbar Ltd (LD) operated the schemes on behalf of the appellants until it later went into liquidation.

HMRC issued to the appellants formal information notices in January 2018. LD engaged Independent Tax...