Sheiling Properties Ltd v The Commissioners for HM Revenue and Customs: [2020] UKUT 0175 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Trower and Judge Thomas Scott on 8 June 2020.

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INCOME TAX 鈥 penalty for non-payment of accelerated payment notice 鈥 is tax demanded under a Regulation 80 PAYE determination 鈥渄isputed tax鈥 within APN provisions 鈥 yes 鈥 did taxpayer have a reasonable excuse for non-payment of penalty 鈥 no 鈥 circumstances in which belief that APN was procedurally invalid could constitute reasonable excuse 鈥 appeal dismissed.

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Published 8 June 2020