PENALTY

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.

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...

Discovery, debt assignment, distribution and penalties: In S Thomas v HMRC [2026] UKFTT 627 (TC) (24 April), the FTT decided that when the company assigned to its controlling shareholder a debt of £2.1m owed to the company by a third party, the...

Stop notice breach: continued scheme operation