The First Tier Tribunal has allowed a taxpayerʼs appeal against HMRC’s late filing penalties. The Tribunal found that the tax returns were issued to collect tax already calculated and ‘assessed’ by the tax payer’s P800s and were not for the purpose of determining the taxpayerʼs taxable income and the amount of tax liability, and therefore could not not meet the statutory requirements of Taxes Management Act 1970, s. 8(1). For this reason, the penalties were held to be invalid.
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