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Private Client Review for February 2019 from Tax Journal

Posted on 25 February 2019. Source: Tax Journal

Private Client Review for February 2019 from Tax Journal

Speed read: In G Pantelli, the First-tier Tribunal (FTT) set aside a self-assessment late filing penalty on the basis that HMRC could not prove that it had issued a valid notice requiring the appellant to file a tax return. In T Raggatt QC, the Upper Tribunal considered whether insufficiency of funds provided a barrister with a reasonable excuse for late payments of income tax due. In R (on the application of T M Jimenez), the Court of Appeal considered whether notices under FA 2008 Sch 36 could have extra-territorial reach so as to require a UK taxpayer resident in Dubai to provide HMRC with the information required to check his tax position. In M Hegarty & Anon, the FTT considered whether an HMRC officer had reason to suspect that there had been an underpayment of tax. In J Charman, the FTT considered an insurance executive’s residence status when ascertaining whether income was taxable in the UK.

Read the full article here.

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