HMRC v Hyrax Resourcing Ltd

In HMRC v Hyrax Resourcing Ltd [2022] UKFTT 218 (TC) (13 July 2022) the FTT granted HMRC’s application for a penalty to be imposed on the company for its failure to notify notifiable arrangements under the DOTAS rules.

In a previous decision ([2019] UKFTT 175 (TC)) the FTT had held that a loan contractor scheme (the ‘Hyrax arrangements’) constituted notifiable arrangements under the DOTAS rules and that the company was a promoter of those arrangements. HMRC therefore applied to the FTT to impose a penalty under TMA 1970 s 98C for the company’s failure to notify the arrangements.

There were three issues for the FTT to consider. The first issue was whether HMRC had shown that the conditions for a penalty had been satisfied and the FTT decided that HMRC had done so. The company argued that no penalty was due because the scheme was...

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