Default surcharge
Appeal, recall of decision of First-tier Tribunal
Appeals
Generally
Payments on account
Application for hearing to be stood over pending House of Lords judgment
Assessment
Amount due
Time limits and supplementary assessments
Assessments
Discretion: judicial review
Estimated in absence of return
Time limits
Certain late returns or payments
Conditions
Credit transfer, payment by extended due date
Defences
Aggravating factors
Breach of regulations
Deemed non-service of surcharge liability extension notices
Double liability
Leaving defaults out of account
No appeal against issue of surcharge liability notice
Non-receipt of return
Non-receipt of surcharge liability notice
Payment to direct tax office in error
Reasonable dispatch of return
Reasonable excuses
Small businesses, special arrangements
Statute-barred excuses
Wrong advice by HMRC
Direct tax treatment
EVAT return and payment, extended due date
General provisions
Generally
Groups of companies
Human rights
Incorrect cheque rendered, duty to correct error
Insolvency
Insufficiency of funds
No mechanism for penalising additional lateness
No return received by HMRC
Offsetting of overpaid VAT
Payment a precondition of appeal being entertained
Payments on account
Amount of surcharge
Conditions for assessing surcharge
Defences to surcharge
Generally
Joining and leaving scheme
Value of defaults
Penalty
Generally
Persons excluded by concession
Post-insolvency returns
Proportionality
Reasonable excuse
Generally
Statute-barred excuses
Restriction of deductions for direct tax purposes
Set-off of credits
Small businesses
Generally
Special arrangements
Subsequent alterations to liability for period
Surcharge liability notice
Ambiguity
Correct rate of assessment
Duration/expiry
Non-receipt
Reasonable excuse
Validity of extension
Withdrawal
Suspension
Currency of agreement for deferred payment
Disaster of national significance
Postal strike
Taxpayer belatedly made payments on account
Time to pay agreement
Case
Generally
Timely but incorrect return
Worked example