Upper Tribunal refuses permission in HMRC Personal Liability Notice case

What was published

The Upper Tribunal refused permission to appeal following earlier findings concerning a £280,903 VAT assessment, a company penalty based on alleged deliberate behaviour and a Personal Liability Notice seeking to make the director personally liable for the penalty. The September decision was a permission-to-appeal decision, not a fresh rehearing of all underlying evidence.

Why it matters

Where HMRC attributes a deliberate inaccuracy to a company officer, the evidence should be broken down carefully: what was inaccurate, who supplied the figures, who maintained the records, how the assessment was calculated, and what evidence supports personal attribution. The procedural stage of the tax appeal is also important.

Wolfe & Black was not involved in this matter. This summary is general information about a published source, not an assessment of your case. We are not a firm of solicitors.