In S Ahmed v HMRC [2020] UKFTT 337 (TC) (17 August) the FTT allowed the taxpayer’s appeal against a penalty for failing to comply with an information notice.
This was because the information notice which was issued on 23 January 2019 and referred to as the third information notice merely repeated two earlier information notices referred to as the first information notice (issued on 11 October 2017) and the second information notice (issued on 30 July 2018). To be valid a penalty notice for failing to comply with the first information notice would have needed to have been issued by HMRC by 20 November 2018 (i.e. within 12 months of the taxpayer becoming liable to a penalty for failing to comply with the first information notice) but no such penalty notice was issued in that time frame; instead a...
