INCOME TAX – non-residents with rental income from UK land but no UK tax liability – penalties under Schedule 55 FA 2009 for failure to file returns – whether reasonable excuse for failure: no – whether Tribunal can make special reduction on account of difference in tax treatment of couples between Ireland and UK: no – whether paragraph 4 daily penalties meet Donaldson criteria: no – whether paragraph 5 and 6 penalties valid: no, as no officer determined penalty to best of information and belief – whether paragraph 17(3) would have reduced penalties to nil in any event: no, dissenting judgment in Shaun C Long preferred – appeals allowed in part.
Citations:
[2018] UKFTT 495 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 31 January 2022; Ref: scu.632261