PENALTY

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

Michael L Firth KC

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

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