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P Baxendale-Walker v HMRC

In P Baxendale-Walker v HMRC [2024] UKUT 154 (TCC) (28 July 2023) the UT struck out an application by HMRC for £14m in tax-related penalties on the basis that there was no reasonable prospect of success. The necessary requirements for issuing the penalty notice had not been met.

Note that publication of this case was delayed and directed on 3 June 2024 after anonymising references to the HMRC officer involved.

On 28 March 2023 HMRC asked the UT to impose a tax-related penalty of £14 031 851.01 on Mr Baxendale-Walker under FA 2008 Sch 36 para 50. A penalty under para 50 can be requested where non-compliance with an information notice continues even after a fixed £300 penalty under para 39 has been issued.

This right is subject to a time limit that HMRC must apply to the tribunal within 12 months of the ‘relevant date’ (para...

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