Tax Penalty and Dispute Newsletter – December 2017
December 1, 2017
By George Rowell and John Flood
The newsletter’s main focus will be appeals against tax penalties, although there will also be other cases and new developments of interest to contentious tax practitioners. Cases will be mentioned either because they break new legal ground or (more commonly) because they illustrate the application of established legal principles in situations often encountered by practitioners.
George is a barrister at Exchange Chambers and John is a retired barrister who was formerly Head of Tax Litigation at HMRC. They are the joint authors of Tax Penalties: A Practitioner’s Guide (Sweet & Maxwell, 2017), which is available for purchase here.
In the December edition:
- Autumn Budget – no news is good news?
- Costs against HMRC
- Daily penalties – validity
- Reasonable care / excuse – ignorance of legal obligation
- Reasonable care / excuse – reliance on agent or employee
- Late filing of appeal
- Schedule 36 Notices – validity and penalties