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As a result of enquiries HMRC concluded the taxpayer was the settlor and sole beneficiary of an offshore trust. It decided he was liable to income and capital gains tax on income and gains that arose to companies owned by the trust under the transfer of assets abroad and settlements legislation (ITA 2007 s 714 et seq ITTOIA 2005 s 619 et seq and TCGA 1992 s 13 and s 87).
HMRC issued an information notice under FA 2008 Sch 36 but the taxpayer failed to respond. Therefore the department issued penalties under Sch 36 para 39 against which the taxpayer appealed to the First-tier Tribunal. However this was rejected because the appeal was incomplete and the taxpayer did not follow it up.
HMRC applied to the Upper Tribunal for a tax-related penalty to be imposed under Sch 36...
