In D Beadle v HMRC [2017] UKFTT 544 (5 July 2017) the FTT found that it does not have jurisdiction in a penalty appeal relating to a partner payment notice (PPN) to consider whether HMRC should have made a different determination of the accelerated partner payment.
Mr Beadle (a member of the Ingenious Film Partners LLP) appealed against a penalty imposed for the late payment of sums due under a PPN. He had made an application under the FTT procedure rules r 5(3)(d) for HMRC to disclose information to him. He believed that information would enable him to establish that the ‘understated partner tax’ calculated by HMRC for the purposes of the PPN was not lawfully due.
The FTT therefore had to determine as a preliminary issue to the substantive appeal whether it had jurisdiction to determine whether the figure of understated tax stated on...
