- UT reinstates follower notice penalty (HMRC v Comtek)
- What are the practical implications of this case?
- What was the background?
- What did the Upper Tribunal decide?
- Meaning of ‘reasonable in all the circumstances’
- Can circumstances after the due date feed into the determination of ‘reasonable in all the circumstances’?
- Reduction of follower notice penalty
- Meaning of ‘counteracted’ for the purpose of reducing a penalty for co-operation
- Case details
Tax analysis: In Comtek, the Upper Tribunal (UT) set aside the First-tier Tax Tribunal’s (FTT) decision and remade it, reinstating the penalty on the taxpayer for failing to take corrective action following the issue of a follower notice, but at a reduced rate of 30% of the denied advantage.
Sign in or take a trial to read the full analysis.
To continue reading this news article, as well as thousands of others like it, sign in to LexisPSL or register for a free trial