R Tager and the personal representatives of the estate of O Tager v HMRC

Cathya Djanogly

In R Tager and the personal representatives of the estate of O Tager v HMRC [2018] EWCA Civ 1727 (20 July 2018) the Court of Appeal reduced the 100% penalty imposed by the UT under FA 2008 Sch 36 para 50.

Mr Tager had submitted his tax returns for the years 2008/09 2009/10 and 2010/11 during the course of April 2012. He had then failed to comply with information notices relating to those returns. In the meantime Mr Tager’s father had died and Mr Tager had become liable to IHT. Again information notices were issued in relation to the IHT return and penalties for non-compliance were imposed. HMRC had applied for permission from the UT to impose a tax-related penalty (FA 2008 Sch 36 para 50).

The UT had imposed a penalty of over £1m (representing 100% of the tax due) for the appellant’s repeated failures...

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