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No explanation for late appeal

08 March 2022
Issue: 4831 / Categories: Tax cases
Delta Tax Agents Ltd (TC8403)
An accountancy services firm with husband and wife directors was registered with HMRC for anti-money laundering purposes. During a compliance visit HMRC found several failings in the firm’s anti-money laundering measures. These included that it did not have a formal policy risk assessment in writing for new clients its policy and procedure documents had not been updated and customer due diligence was not always carried out fully.

In June 2018 HMRC issued a penalty of £16 891. The company had 30 days to accept an offer of a review but failed to apply until January 2019. HMRC refused to undertake the review and the company applied to the First-tier Tribunal to make a late appeal. 

The tribunal noted the delay in appealing was more than six months. This was ‘serious and significant’. The judge noted that although the husband had been ill during some of the...

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