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Making late notifications to HMRC—the importance of acting and proving you have acted proactively and promptly (Ketley v Revenue and Customs Commissioners)

Published on: 21 September 2021
Published by: LexisPSL
  • Making late notifications to HMRC—the importance of acting and proving you have acted proactively and promptly (Ketley v Revenue and Customs Commissioners)
  • What are the practical implications of this case?
  • What was the background?
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Article summary

Pensions analysis: The Upper Tribunal (UT) held that, for the purposes of Regulation 12 of the Registered Pension Schemes (Enhanced Lifetime Allowance) Regulations 2006, (the EP Regulations), while the taxpayer had a reasonable excuse for not having given the requisite notification to HMRC before the closing date of 5 April 2009 to protect the value pension accrued before 6 April 2006 (A-Day) from the income tax charge above the lifetime allowance imposed by the Finance Act 2004 (FA 2004), he had not acted without unreasonable delay when he made his late notification after the reasonable excuse had ceased. Written by Oliver Hilton, barrister at Radcliffe Chambers. or take a trial to read the full analysis.

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