Suzie Moore explains why taxpayer behaviours are under increased HMRC scrutiny when they consider the application of tax-geared penalties.
Finance Act 2007, Sch 24 is a behaviour based regime for the imposition of tax-geared penalties. The focus of the regime from HMRC’s perspective is to reward what they perceive as ‘good’ taxpayer behaviour and reduce or eliminate what they perceive as ‘poor’ taxpayer behaviour. This article focuses on the boundary between reasonable care and carelessness when an agent has submitted the tax return, as an illustration of the increasingly forensic and challenging positions we have seen HMRC adopt in practice and in the appeals about tax-geared penalties they pursue at the tax tribunals.
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*First published in Taxation on 9 May 2019. Reproduced with permission.
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