– see also Late payment of VAT

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

– see also 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