Legal News

UT reinstates follower notice penalty (HMRC v Comtek)

Published on: 07 April 2021
Published by: LexisPSL
  • 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

Article summary

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. or take a trial to read the full analysis.

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