PENALTY

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

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

Stop notice breach: continued scheme operation

The Court of Appeal’s reasoning in Sintra Global misses key principles and authorities, writes Michael Firth KC (Gray’s Inn Tax Chambers).

Residency dispute and appeal against self-assessment penalties 

Court of Appeal considers burden of proof in penalty appeals 

Costs awarded because of taxpayer’s unreasonable conduct: In HMRC v Mattu [2025] UKUT 410 (TCC) (16 December 2021), the UT awarded HMRC £5,000 in costs under rule 10(3)(d) of the UT rules (SI 2008/2698), confirming that there is no requirement for a...

FTT imposes penalty on promoter of notifiable annuity-based umbrella arrangements.

Upper Tribunal follows Medpro when applying Martland three-stage test, but still refuses late appeal application