Priory London Limited v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v Jocoguma Properties Limited [2022] UKUT 00225 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Zacaroli and Judge Ramshaw on 12 August 2022
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Annual Tax on Enveloped Dwellings - Late filing of returns - Daily Penalties - Paragraph 4 of Schedule 55 to Finance Act 2009 – Paragraph 4(3) provides that the date specified in a notice under paragraph 4(1)(c) from which a daily penalty is payable can be prior to the date the notice is issued. HMRC appeal allowed.