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S Dolan v HMRC

In S Dolan v HMRC [2020] UKFTT 448 (TC) (4 November 2020) the FTT considered an appeal against a penalty for an inaccuracy in a tax return determining that the inaccuracy was careless rather than deliberate.

The taxpayer was a qualified accountant but had not practised for a number of years. In July 2013 he moved to Monaco and he completed his tax return for 2013/14 (the first year for which the statutory residence test applied) on the basis that he was not UK-resident for the year. Following an HMRC enquiry Mr Dolan accepted that split year treatment applied with the result that his tax liability was significantly higher than shown in the return. HMRC considered that the inaccuracy in the return was deliberate and issued a penalty assessment under FA 2007 Sch 24 with a penalty percentage of approximately 47%.

The FTT accepted Mr Dolan’s...

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