Peter Marano v The Commissioners for HM Revenue and Customs [2023] UKUT 00113 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Fancourt and Judge Vimal Tilakapala on 17 May 2023
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PROCEDURE (i) automated notices requiring returns – effect of s 103 FA 2020, (ii) whether service provisions of s 115 TMA 1970 are the only means of giving notice of penalty assessments PENALTIES (i) whether computation of tax geared penalties under paras 5 and 6 Schedule 55 FA 2009 should take into account prepayments of tax, (ii) scope of “special circumstances” justifying penalty reduction