PENALTY

Another procedural layer bolted onto an already intricate system.

Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.

Tom O’Reilly Jan Kolasa Ben Webster

Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.

Sophie Rhind

Elvira Colomer Fatjo

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Liam McKay

Adam Craggs

Adam Craggs and Liam McKay (RPC) review some notable rulings on a range of procedural issues, as well as recent changes to the tribunal rules.

SKAT fraud claim survives issue estoppel challenge: Readers may recall SKAT’s attempt to pursue a fresh fraud claim in England against MCML, formerly ED&F Man Capital Markets Ltd, over allegedly false tax vouchers used to obtain Danish...

Follower notices and corrective action: C Maguire v HMRC [2026] UKFTT 929 (TC) (18 June) is a rare example of a taxpayer succeeding in an appeal against a penalty for failing to take corrective action after receiving a follower notice. The taxpayer...

Penalties: reliance on trusted accountant

Re-litigating the same issue

Income tax and VAT assessments: In J Smith v HMRC [2026] UKFTT 663 (TC) (6 May), the FTT upheld HMRC’s income tax and VAT assessments and most penalties, while reducing the quantum and cancelling failure-to-file penalties where notices to file had...

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