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A Newton (TC6269)
Penalties for return submitted after deadline
The taxpayer filed his 2012-13 tax return late. HMRC imposed penalties against which the taxpayer appealed. He said that although there had been an advertising campaign about the higher penalties that would apply to late filed returns for that year it had been restricted to the UK. However he was non-resident living in Paris and had not seen the advertisements.
The First-tier Tribunal said the taxpayer did not have a reasonable excuse. But there were special circumstances. It was clear from the taxpayer’s return that he was not liable to UK tax in the year. Further he did not have a permanent UK establishment and as a result under art 7(1) of the double tax convention with France the UK had no taxing rights over him.
In these circumstances he did not meet the...
