Jack Prytherch examines the issues around a failure to file returns by third parties and the imposition of ‘deliberate’ penalties.
In H Dhaliwal v HMRC [2020] UKFTT 463 (TC), the First-tier Tribunal (Tax Chamber) held that, when determining whether there was deliberate behaviour for penalties where a taxpayer has delegated the filing of tax returns to another person, HMRC must show that the other person has deliberately failed to file the return. The decision has important implications for agents who regularly file returns on behalf of clients.
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