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Dr B Rai v HMRC

In Dr B Rai v HMRC [2017] UKFTT 467 (6 June 2017) the FTT found that a letter sent by the taxpayer’s accountant following receipt of a partner payment notice (FA 2014 Sch 32) did contain representations so that the non-payment penalty issued by HMRC should be cancelled.

Dr Rai appealed against three penalties for failure to make three partner payments by the end of the payment period. The partner payment notices (PPN) had been issued in relation to his involvement in a film scheme.

The FTT first observed that the partner payment notices met all the statutory requirements. The issue was therefore whether the PPN amounts were unpaid at the end of the payment period. This depended on whether representations had been made.

Dr Rai’s accountant had sent a letter to HMRC but it denied that the letter contained representations. Agreeing with Dr Rai the FTT...

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