In Glasby v HMRC [2020] UKFTT 352 (TC) (3 September) the FTT upheld penalties in respect of failure to take the corrective action required under follower notices but reduced the amount of the penalties to 20% of the tax arising from the denied advantage.
The taxpayer had entered into an IR35 scheme known as ‘Working Wheels’ in 2006/07 and 2007/08. In November 2016 HMRC issued accelerated payment notices (APNs) and follower notices (FNs) to the taxpayer for each of the tax years. Under the FNs Mr Glasby was required to take corrective action to relinquish the tax advantage under the scheme by 24 May 2017. He did not do so until May 2018 and HMRC issued penalties under FA 2014 s 208. The maximum penalty was 50% of the denied tax advantage and applying their policy on reduction for cooperation HMRC initially charged penalties of...
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