Sheiling Properties Ltd v The Commissioners for HM Revenue and Customs: [2020] UKUT 0175 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Trower and Judge Thomas Scott on 8 June 2020.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 8 June 2020

• Category: Tax
• Release date: 8 June 2020

Read the full decision in Sheiling Properties Ltd v The Commissioners for HM Revenue and Customs: [2020] UKUT 0175 (TCC).

INCOME TAX – penalty for non-payment of accelerated payment notice – is tax demanded under a Regulation 80 PAYE determination “disputed tax” within APN provisions – yes – did taxpayer have a reasonable excuse for non-payment of penalty – no – circumstances in which belief that APN was procedurally invalid could constitute reasonable excuse – appeal dismissed.

Published 8 June 2020