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G Corrado v HMRC

In G Corrado v HMRC [2019] UKFTT 275 (25 April 2019) the FTT set aside a penalty imposed for failure to take corrective action following the issue of a follower notice (FN).

Mr Corrado had implemented a tax avoidance scheme known as ‘working wheels’ and he appealed against a penalty imposed for ‘failing to take corrective action’ on receipt of an FN. Both the FN and the related accelerated payment notice (APN) had wrongly stated that the ‘additional tax due and payable’ was £191 803.60 when the amount due was only £16 580.29. Mr Corrado’s accountant and HMRC agreed that only the lower amount was due which was then paid by Mr Corrado.

The main issue was whether Mr Corrado had taken corrective action in respect of the benefit which had now been denied by the Flanagan [2014] UKFTT 175 decision (FA 2014 s 208).

The FTT found that the...

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