Another case that caught our eye: 9 June 2023

Late filing penalties re ATED return: In Hughes Property Partners Ltd v HMRC [2023] UKFTT 453 (TC) (25 May) the FTT dismissed the taxpayer’s appeal against late filing penalties charged under FA 2009 Sch 55 for filing of an ATED return eight months late. The taxpayer appealed the penalty on the basis that there had been enormous pressure on accounting firms during the Covid pandemic and that it had been difficult to get in touch with HMRC at the time given that they were working remotely. It was further argued that HMRC did not request the taxpayer file an ATED return for this particular property while it had sent notifications about its obligations to file for other properties and that there was no loss of tax by HMRC on the late return as the tax liability was nil. HMRC declined to cancel the penalty because no reasonable...