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S Thompson v HMRC

In S Thompson v HMRC [2024] UKFTT 138 (TC) (12 February 2024) the FTT considered an appeal against an inaccuracy penalty by an IT consultant. It held that the inaccuracies had not been deliberate but the taxpayer had been careless. 

The taxpayer was an employee working in IT until 2013 when he decided to go out on his own as an IT consultant. He obtained work via an organisation (BFB) specialising in IT contracting believing that he would be paid by them under deduction of PAYE and NIC. The arrangements were not entirely clear to the tribunal but he also received payments in respect of his services from another entity (Atlas Trustees Ltd). Neither BFB nor Atlas deducted PAYE and NIC. 

Mr Thompson’s tax return for 2013/14 included income from his employment but not the payments from BFB and Atlas. Following an enquiry HMRC wrote to him...

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