Absolute trusts

Accelerated payment notices

Accounts investigation

Acquisition cost to be determined at market value

Acquisition of company in which appellants and many others held shares, subscription of which qualified for EIS relief

Additional rate

Ademption not applicable to

Administration period income

Administration expenses

Allowances, not available

Amending returns

Apportionment of income

Beneficiaries with interest in residue

Beneficiaries, circumstances of

Beneficiaries, tax position

Categories of income arising, expenses thereon

Complex estates

Death of residuary beneficiary


Double tax, income of estate and administration period


Foreign income of non-UK domiciled deceased

General legacies


Income of administration period or of deceased

Informal payment procedures

Interest paid

Interest received

Pecuniary legacies

Rates of tax

Reporting requirements

Residuary beneficiary, distributions to by PRs

Residuary beneficiary, double tax relief

Residuary beneficiary, income of administration period

Residuary beneficiary, with interest

Residuary legacies

Specific legacies

Successive interests in residue

Agency rules deem single employment for all assignments

Agency workers entitled to tax relief on journeys from home to first location

Agent authorisation

Allegations of duress

Alleged suppression of takings

Alleged under-declaration of trading income


Amount of taxable property income

Amounts deducted under Finance Act 2004, Pt. 3, Ch. 3

Annual payments

Annual tax

Annuities (FA 2015 changes)


Appeal against

Absence of direct evidence that shares issued

Accelerated payment notice

Additional assessments to income tax under Income and Corporation Taxes Act 1988, Sch. E

Amendment to return

Amendments to self-assessment return

Appellant subscribed for shares in the company

Assessment allowed

Assessment of balancing payment in respect of 2014–15

Assessment of penalties

Assessments under Taxes Management Act 1970, s. 29

Assessments under Taxes Management Act 1970, s. 36

Attempt to change accounting date failed

Circumstantial evidence sufficient to infer that subscription had taken place

Claim to share loss relief under ITA 2007, s. 131 and 132

Claims for trade loss relief against general income

Closure notice

Closure notice and an inaccuracy penalty

Closure notice disallowing certain losses

Closure notices and amendments

Complaint against HMRC conduct reasonable excuse

Daily penalties

Daily penalties imposed by HMRC for failing to comply with information notices

Default surcharge

Development of a tree surgery and woodmanship trade from a domestic concern

Direction notice requiring appellant to pay income tax and interest in respect of untaxed remuneration

Disallowing claims for sideways loss relief of farming losses

Disallowing claims to foreign service relief in respect of a termination payment

Disallowing EIS relief

Disclosure notice

Discovery assessments

Discovery assessments made by the National Crime Agency (NCA)

Finance Act 2008 (FA 2008), Sch. 36 notices and against penalties

Gross assets test failed, liabilities exceeded assets

High income child benefit charge

HMRC amendments relating to disallowance of loan interest and legal costs upheld

HMRC direction notices under PAYE regulations

HMRC incorrectly disallowed expenditure

HMRC's amendment on discovery assessments

HMRC's amendment on self-assessment

HMRC's assessments disallowing claims to set off farming losses against other income

HMRC's closure notice in respect of self-assessment returns

HMRC's decision to disallow claims to offset trading losses against other income

HMRC's decision to pay Class 1 National insurance contributions

HMRC's decision to refuse to accept late notice of intention

HMRC's decision to require security for VAT, PAYE and NICs

HMRC's refusal of relief under the Income and Corporation Taxes Act 1988 (ICTA 1988)

HMRC's refusal to issue a direction under Income Tax (Pay As You Earn) Regulations 2003

Inaccuracy penalty

Income from letting holiday cottages property or trading income

Information notice issued under Finance Act 2008, Sch. 36 and related penalties

Information notices issued under Finance Act 2008 ('FA 2008'), Sch. 36

Interest charged under Taxes Management Act 1970, s. 86

Lack of written notice of appeal to HMRC

Late filing of self-assessment returns and late payment of taxes due

Late filing penalty

Late payment penalty

Late personal tax return filing penalties

Late submission of self-assessment tax returns

Legal costs eligible for post cessation trade relief

Loss arising in trade subject to corporation tax

Loss on disposal of shares an 'allowable loss' for capital gains tax purposes

Loss relief restriction under Income Tax Act 2007, s. 67

PAYE and NI determinations under Income Tax (Pay As You Earn) Regulations 2003, reg. 80

PAYE and NI determinations under Social Security Contributions (Transfer of Functions) Act 1999

PAYE Determination and NIC Decisions for tax year 2004-05

Payment of discretionary bonuses to a remuneration trust structure

Penalties following third party information

Penalties for errors made in submission of self-assessment tax return

Penalties for late filing of 3 NRCGT returns

Penalties for late filing of NRCGT returns

Penalties for late filing of partnership tax return

Penalties for late filing of tax return

Penalties for late payment

Penalties for late submission of returns

Penalties for not filing return on time

Penalties under FA 2009, Sch. 55 for failure to file partnership return

Penalties under Finance Act 2007, Sch. 24

Penalties under Finance Act 2008, Sch. 36, Sch. 41

Penalties under Finance Act 2009, Sch. 56

Penalty assessment

Penalty assessment for failure to deliver return

Penalty assessment for prompted disclosure of careless inaccuracy in tax return

Penalty assessment for prompted disclosure of deliberate inaccuracy in tax returns

Penalty determination for careless behaviour, Finance Act 2007, Sch. 24

Penalty for careless inaccuracy professional advice taken

Penalty for failure to deliver partnership return

Penalty for failure to deliver returns on time

Penalty for failure to file partnership return

Penalty for failure to make returns

Penalty for inaccuracy due to failure to take reasonable care

Penalty for late filing of SA return

Penalty for late submission of self-assessment tax returns

Penalty for not taking corrective action following the issue of a follower notice

Penalty imposed for careless inaccuracies

Penalty imposed for negligence in completing return

Penalty under FA 2009, Sch. 55, para. 3, late filing of self-assessment tax return

Penalty under FA 2014, s. 226 and Sch. 32, para. 7

Penalty under TMA 1970, s. 95

Power to amend a taxpayer's self-assessment return

Property income not part of farming business

Quantification on evidence; set off of losses against other income

Security for payment of PAYE and NICs

Security for payment of VAT

Self-assessment closure notice, in specie contribution to funded unapproved retirement benefits scheme

Self-assessment closure notice, trade loss relief against general income

Self-assessment returns filed out of time to displace determinations

Sideways loss relief

Sum of money received as gift or payment for a service

Surcharges for late payment

Taxpayer 'ordinarily resident' during tax year of disposal

Taxpayer discharged burden of proof

Taxpayer entitled to further credit for foreign tax Taxation (International and Other Provisions) Act 2010, s. 18

Taxpayer took reasonable care to avoid inaccuracy in tax return

Termination payment

Travel, subsistence and training expenses claimed

Various discovery assessments and penalties in substance

VAT assessment and a direction to amend VAT return

Whether expenditure on rights to income from films was capital

Whether reasonable excuse for late payment for individual tax return

Whether reasonable excuse for late submission of individual tax return

Appeal out of time

Application for permission

Reasonable excuse

Reasons for delay

Reliance on a third party accountant

Appeal rights against penalties for late filing


– see Appeals

Appellant buying and selling listed shares with view to profiting from short term movements in prices

Appellant claimed certain deductions against capital gains tax on sale of shares

Appellant entitled to income of an Isle of Man partnership

Appellant liable to pay Class 1 National insurance contributions

Asset made available and half owned by director

Benefit in kind calculated under ITEPA 2003, s. 205

Yacht purchased in company name

Appellant liable to pay under-deducted tax

Appellant not representative partner

Appellant received company benefits in kind

Benefits received by appellant from husband as part of a maintenance agreement


Appellant seek permission to notify late

Appellant sub-postmaster receiving termination payment on closure of sub-post office

Appellant within agency rules

Appellant's failure to amend PAYE coding for one employee

Applicability of Ramsay principle

Application for

A decision to be set aside

Admission of late appeal

Allocation to complex category

Appeals to be admitted out of time

Closure notice under Taxes Management Act 1970, s. 28A(4)

Closure notices under Taxes Management Act 1970, s. 28B

Deductibility of expenses

Enhanced protection

Erroneous rebate

Extension of time limit to allow admission of a late appeal

Extension of time of over three years for notifying an appeal to the tribunal

Extension of time, making of an appeal to the Tribunal

Interim relief

Interim relief in the form of an order

Judicial review to limit benefits available under LDF in relation to employee benefit trust schemes

Late appeal

Permission to admit appeal out of time

Permission to appeal late

Permission to make late appeal against income tax assessments

Permission to make late appeal against penalty determinations

Permission to make late appeal under Taxes Management Act 1970, s. 49

Permission to make late appeals

Permission to make late appeals against assessments and penalties

Permission to make late appeals against three discovery assessments

Permission to make late appeals against two enquiry closure notice amendments

Permission to notify appeal refused

Stay pending enquiry and expected proceedings relating to partnership of which appellant a former partner

Strike-out under Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009

Tribunal to direct HMRC to issue closure notice under Taxes Management Act 1970, s. 28A

Application of Income Tax (Trading and Other Income) Act 2005

Application of inter-governmental agreement

Application of ITEPA 2003

Application of Taxes Management Act 1970, s. 29 and s. 36

Application of yearly Income Tax Acts

Application to amend grounds of appeal to rely on further grounds

Application to appeal out of time

Discretion of tribunal


Reasons for lateness

Reliance on third-party accountant

Application to be heard in private

Application to bring late appeal

Bankruptcy proceedings


Application to close enquiry

Application to extend time for appeal

Application to make a late appeal against an income tax assessment

Application to postpone payment of tax

Reasonable grounds for believing appellants overcharged by assessments

Application to reinstate appeal struck out for failure to comply with an 'unless order'

Application to reinstate various tax related applications

Application to restrict the scope of an appeal

Apportionment of income

Arrangements for exploitation of intellectual property rights



– see Assessments

Assessments, time limits for

Asset made available and half owned by director

Assignment deemed to be a separate employment

Avoiding probate

Back duty investigation

Bad debt relief

Balancing exercise undertaken

Basic rate

Basis of assessment

– see also Assessments


Basis periods

– see Basis periods

Benchmark travel rates

Benefit of taxable cheap loan treated as earnings

Benefits in kind

Benefits treated as earnings

Best judgment

Building societies

Business carried on together with stationery shop

Business expansion scheme

Business profits

– see also Business profits


Buy-out payments, termination of employment

By-pass trusts

Cap on reliefs

Excluded reliefs

Limited reliefs

Capital gains tax

Allowable deductions

Costs of acquisitions and disposals

Decisions and assessments

Lease premiums

Relief on disposal of private residence

Value shifting

Capital taxed as income

Car benefit

Car benefit chargeable on the appellant

Car leased to employee

Car made available to employee


Cash equivalent calculated without regard to any capital contribution made

Cash takings inconsistent with debit/credit card receipts

Certificate of non-liability

Cessation of optician's franchise business

Carry forward of loss from franchise business claimed

Optician working as a locum




Charge on conversion of employment-related convertible securities

Charge on pension scheme administrator on cessation of approval of scheme

Charge to tax


Bodies of persons

Capital amount

Civil partners

Executors and administrators

Friendly societies

Incapacitated persons

Income arising


Married couples

No CGT charge

Notification of chargeability

Personal representatives


Residual charge

Taxable persons


Charge to tax on date with effect from which approval is withdrawn

Child benefit high income charge

Claim for capital allowances of expenditure on scientific research

Claim for loss on disposal of loan stock

Loan stock not a relevant discounted security

Payment of premium on redemption of loan stock was interest

Claim for overpayment relief

Claim for special relief under Taxes Management Act 1970, Sch. 1AB, para. 3A

Claim under Income Tax Act 2007, s. 131 for share loss relief against income

Claimants sought judicial review challenging legality of accelerated payment notices (APNs) and partner payment notices (PPNs)

Claiming benefit of an extra-statutory concession , HMRC giving up arrears of tax

Claims for reliefs and allowances

Closure notice



Charged from appellant's companies to appellant

Disputed expense claims for consultant work

Evidence of services supplied

Onus on taxpayer to demonstrate that expenses properly incurred for purposes of trade


Trade loss relief against general income

Underpayment identified on PAYE record


Commuting employees


Chargeable persons


Interest on overdue tax

Companies, due and payable dates

Companies, Form CT61 procedure

Company ceased trading

Compensation for departure from a contract of employment following a TUPE transfer

Compensation for loss of rights to a reward and benefit scheme

Composite rate, building societies




Taxable income

Computation of profits


Circumstances of late appeals and of merits of substantive appeal sought to be brought

Decision not to allow late appeal in all circumstances

Construction industry scheme


Contract of service (employment) or contract for services

Conversion of deferred shares into ordinary shares

COP9 investigation

Cost of cars purchased by appellant

Credit for foreign tax on overlap profits

Clawback of relief


Time limits for claims

Death benefits (pension)

Deceased's liability before death

Decision of tribunal in principle

Allegations by appellant, tribunal misled by HMRC's witness

Calculation of penalties of settlement offer by appellant, relevance of

Disability of taxpayer

Efficiency, proportionate cost and compliance with rules outweighs other circumstances


Hearing adjournment, parties to determine figures

Jurisdiction to consider interest calculation and charge

Quantification of income and capital gains tax due

Taxpayer and adviser both responsible for delay

Deduction of tax at source

Deduction of trading losses


Deed of variation (no effect)

Deferred earnings



Departing from the UK

Determination/decision issued on undeclared employer liabilities from employment of workers

Development gains

Differing types of trust (overview)

Digital reporting and record-keeping

Digital reporting and record-keeping requirement




Discovery assessment

Additional capital gains tax

Amount of appellant's profits from motor business

Amount of appellant's rental income

Appellant asserted for incorrect discovery assessment

Appellant carrying on trade of operating a beach café

Appellant had undeclared business income

Appellant's electronic tax return caused income tax refund

Benefits code for cars and fuel

Claim for set off of tax credit made

Conditions for discovery assessment met Taxes Management Act 1970, s. 29(4)

Effect of pool car treatment give rise to discharge or repayment of tax

Error in tax return

Errors attributable to online submission difficulties

Evidence to displace assessments


Issued under extended time limits

Loss of tax due to careless behaviour

Loss of tax resultant from incorrect entries on tax returns

Non-attendance of appellant

Restriction of 'sideways offset' of losses derived from capital allowances in respect of yacht chartering

Section 95 and schedule 24 penalties

Unauthorised payments charge and unauthorised payments surcharge

Validity of

Discretionary trusts

Discretionary will trusts

Dishonest conduct

Dispositions allowable as deductions

Dispositions allowable for

Disregarded income calculation

Limited liability for non-residents

Savings income

Self-assessment compliance

Distributions from non-UK resident companies

Dividend income

Dividend income from company, appellant was director and shareholder


Dividends and other distributions

Dividends, basis of assessment

Domicile (deemed)

Double tax relief

Double Tax Treaties

Double taxation arrangements, giving effect to

Earned income


Earnings from employment

Earnings from UK work days

Earnings from UK workdays

Effect of Confiscation Order

Effect of partial surrenders of insurance policies by individual

Effect of reference in account to fish stocks

Electronic filing requirement, impact of


– see Earnings

Employee benefits

Employee working on various different sites for periods of less than two years

Employer-financed retirement benefit schemes

Employers Annual Returns

Employee on maternity leave overlooked filing of P35

Ignorance of obligation to file return

Late appeal for filing of 2009/10, 2010/11 and 2011/12 returns

Late filing due to illness

Late filing of P11D, agent's oversight

Late filing of P11D, employer alerted by lack of acknowledgment

Late submission, failure by Appellant's agent to file employer's end of year P35 return

Late submission, not filed by previous clerk

P35 and P14 return

Penalty for late submission

Post-cessation filing delegated to agent

Employers deducted correct tax from appellant under PAYE

Employment income

– see also Employment income


Employment intermediaries

Employment status

Employment tax treatment of travel and subsistence arrangements

Employment-related loans

Enquiries opened within time limit

Enquiry closure notices

Application for

Denial of tax credits of dividends received from non-UK resident companies

Interpretation of legislation rewritten as part of the Tax Law Rewrite Project

Self-assessment tax return

Enquiry into self-assessment

Enterprise investment scheme


Entitlement to annual investment allowance (AIA)

Equitable liability claimed

Failure by HMRC to consider equitable relief outside jurisdiction of tribunal

Estates in administration

Estimated assessments

Excepted group life policies

Exception for loan on ordinary commercial terms

Excess repayable to employee directly

Excluded property trusts

Exclusion where expenditure incurred in chargeable period in which trade permanently discontinued

Exempt income

– see Exempt income



Exemptions and reliefs


Glasgow grand prix

Married couples and civil partners

Tax exemptions for major sporting events

Expenditure incurred wholly and exclusively for purposes of trade

Failure by respondents to comply with tribunal instruction

Failure to comply with directions

Failure to file employer's annual return P35

Company changed name during tax year


HMRC software unable to accept change of name

Failure to keep accurate records

Failure to notify chargeability

Failure to notify obligation to register

Failure to pay on time

Failure to submit accurate self-assessment returns

Filing of return

Film partnerships

Partnership trading losses

Film tax relief

Partnerships acquiring and leasing back interests in three films

Sideways and early-years loss relief

Finance Act 2008, Sch. 36 notice

Financial information of spouse not disclosed due to secrecy

Finding of fact

Benefit from use of cars taxable as remuneration from relevant employment

Fixed rate notes stripped of interest coupons

Flexible trusts

Floating rate notes stripped of intermediate interest coupons

Foreign earnings deduction

Foreign field

Forfeiture of relief in relation to Enterprise Investment Scheme

Forgivable loan

Form 64-8

Form P85

Formal determination of figures on appeal by requesting parties

Fraudulent evasion

Freedom of establishment

Fuel benefit

General legacies


Gift aid

Gift Aid donations

Gifts of assets

Gifts to the nation

Government bonus for savings account

Government Gateway


Non-resident landlords

Personal tax accounts

Registration with

Heads of charge post-6 April 2005

Higher rate

Historical background


Capital allowances

Deduction at source

Double taxation relief



Schedular system


HMRC alleging undeclared trading income

HMRC determinations for 2002/03 to 2007/08

Claim for special relief

Unconscionable to pursue recovery of tax

HMRC determinations for 2005-06 and 2006-07

Appellant out of time to displace determinations


HMRC determinations for 2006-07 and 2007-08

Appeal against refusal to grant special relief upheld

Appeals against surcharges and penalties

Appellant out of time to displace determination

Claim for special relief

Enforcement of determination unconscionable

Reasonableness of HMRC's decision on enforcement

Self-assessment returns filed out of time to displace determinations

Unreasonable in a judicial review sense

HMRC information notice


Authorised officer, meaning

Bank statements, statutory records

Daily penalties for non-compliance

Document reasonably required for purposes of checking taxpayer's tax position

Giving of a third party notice by the National Crime Agency

Interaction with directions under Insolvency Act 1986

Irrelevance of representations on liability and assessment processes

Jurisdiction and territoriality

No right to a public hearing


Patient confidentiality

Power of a bankruptcy registrar

Proceeds of Crime Act 2002, s. 317

Request for information under Finance Act 2008, Sch. 36, para. 1

Restricted right of appeal

Taxpayer and third party given notice of hearing

Taxpayer notice

Third party information notice

Validity of

HMRC's allocation reasonable other than for 2005-07 tax years

Holder of the employment, meaning

House of Commons resolutions, temporary statutory effect of

Husband and wife

Immovable property

Inaccuracies in tax return


Discovery assessment

Dividend income from company, director and sole shareholder paid in part to appellant's partner

Failure by taxpayer to include various items


Overstated travelling and subsistence expenses

Penalty assessment

Penalty under Finance Act 2007, Sch. 24

Revenue amendments

Inadequacy of records

Income arising before/after death

Income distributed to beneficiaries

Income in trust

Income received without deduction of tax

Income Tax (Trading and Other Income) Act 2005, position under

Income undeclared in light of family household expenditure

Income, meaning

Incorrect returns

Incorrect tax year assessments

Individual savings accounts

Individual sub-trusts

Industrial buildings allowance

Building leased by health board for use as laundry

Commercial building in enterprise zone


Interaction between agency rules and employee travel rules

Interaction of taxes

Interaction with inheritance tax IHT200 form

Interaction with VAT


Certificates of tax deposit

Late payment interest

Repayment interest

Interest deductions claimed as part of tax avoidance scheme

Interest in possession trusts

Interest on money paid under unauthorised demand

Interest payments made by a UK company to offshore trusts/companies

Interest relief

Interest relief on loan

Interest, basis of assessment

Interpretation of Double Tax Treaty


Investment bonus paid to hedge fund managers, transfer from one company to another

Investment income

– see also Investment income



Jamaican, director's personal liability

Late application for a full decision

Appeal against HMRC penalty decision for late submission of P35


Late applications for reinstatement

Late filing of returns

Appellant no access to internet

Appellant subject to PAYE

Daily penalties

Delay by HMRC in notifying appellant of penalties

Forms P35 and P14


HMRC's discretion to mitigate penalties

Hotel internet down



Individual tax return

Intentionally misled by accountant

Late lodging, lack of communication between accountant and director

Mistake or misunderstanding


One day late

Penalty under Finance Act 2007, Sch. 24

Penalty under Finance Act 2009, Sch. 55

Penalty under Finance Act 2009, Sch. 55, para. 3

Penalty under Finance Act 2009, Sch. 56

Penalty under Regulation 73 Income Tax (PAYE) Regulations 2003/2682

Penalty under Section 98A (2) and (3) Taxes Management Act 1970

Penalty under Taxes Management Act 1970, s. 95

Problems with online submission

Reasonable excuse

Reliance on accountant

Reliance on third party endorsed by HMRC amounted to reasonable excuse

Self-assessment tax return

Special circumstances

System not properly set up to deal with Form P35

Taxpayer abroad

Test filing

Third party responsibility, indisposition

Trust &estate tax return

Two penalty notices

Late filing of self-assessment return

Fixed and daily penalties


Penalty under Finance Act 2009, Sch. 55, para. 3

Late notice of appeal

Late payment

30 day, 6 month and 12 month penalties

Amount of penalty, accurate

Bank holidays alleged to be at one time to pay date

Cancer treatment, reasonable excuse

Change of address by taxpayer

Conduct of HMRC, special circumstances


First and second surcharges


Individual tax return

Payment made late

Penalty of in-month PAYE

Penalty reduced

Penalty under FA 2009, Sch. 55

Penalty under FA 2009, Sch. 56

Penalty under Section 59C (3) and (4) Taxes Management Act 1970

Permission to appeal out of time

Reasonable excuse

Reliance on statements from HMRC that no penalties charged

Self-assessment return

Self-assessment tax liability

Special circumstances


Taxpayer unfamiliar with UK tax regime

Time to pay arrangement, agreed with HMRC

Late payment penalty

Late submission

11 CIS returns during the period November 2011 to September 2012, reasonable excuse

Alleged lack of clarity of site

Employer's P35 returns


Individual tax return

Lack of web literacy

Misunderstanding HMRC website

PAYE return

Reasonable excuse

Self-assessment returns

Software difficulties caused by migration to real time information (RTI)

Unclear advice from HMRC

Lease arrangement falling within Income Tax (Earnings and Pensions) Act of 2003 ('ITEPA 2003')


Legislation for avoidance of double taxation


Basis periods 2004–05

– see Basis periods


– see Deductions


Non-resident companies

Non-resident individuals

– see Non-residents


Liability and reliefs

Liability of directors for unpaid PAYE liabilities of liquidated company

Liability of employee under employment contract to refund a proportion of a taxable signing bonus

Liability of PRs

Liability, HMRC's ability to set off against VAT repayment due

Liechtenstein Disclosure Facility (LDF)

Lifetime allowance

Lifetime transfers

Limit on tax liability

Limited liability partnership


Basic rate from 2016


Limits on/reduction of credit for foreign tax

Accrued income loss

Amount of limit


Trade income

Lloyd's underwriters

Loan on ordinary commercial terms

Loan treated as earnings

Loan used to buy investment property


Loss relief

– see Loss relief


– see Losses

Lower rate

Lump sum death benefits

Maintenance payments

Making tax digital


Capital or income receipts

Investment income

One or more businesses

Managed service companies

Provider benefits financially from provision of services by the individual

Provider involved with appellants

Mandated income

Married couple

Married couple's allowance

Married persons

Mauritius, repayment of share capital, retrospective legislation


Mileage allowance payments

Mileage allowance relief under ITEPA 2003, s. 231

Mileage allowance relief under ITEPA 2003, s. 232

Moneys paid as accommodation allowances

National insurance contribution

Allowances for travel and subsistence costs

Appeals settled by agreement

Award of bonuses

Cheap loans

Class 4, associated penalties and VAT dishonest evasion penalty

Computation of profits of accounting business and property business


Discount agreement

Employee benefit trust

Employee given free bus pass by employer

Employees working for different companies

Exempt from tax under Income Tax (Earnings and Pensions) Act 2003, s. 243

Flat conversion allowances validly claimed

Intermediaries legislation

Liability of directors for unpaid PAYE liabilities of liquidated company

Link to non-cash voucher legislation

Loan notes

Premiums paid by employer on insurance policies relating to director

Restricted securities

Scheme to deliver bonuses in form of shares avoiding income tax and NICs

Nature of payments of statutory interest under the Insolvency Rules 1986

Nature of payments of statutory interest under the Insolvency Rules 2016

Negligible value claim

New Zealand

Group relief deductions

Sale of land, computation of profits

Tax avoidance, financing production of feature films


Non-resident companies

Non-resident, charge on


Northern Ireland

Notice of appeal notified any appeals within the tribunal's jurisdiction

Notice of liability to tax

Notification of chargeability

Offset of trading losses against income

Offshore trusts

Omission of a source of income from self-assessment return, prepared by accountants

On establishing trust

Oneoff contribution to appellant's SIPP over special annual allowance charge limit

Ordinary and deferred shares

Original assessment in 2007

Out of time claim for overpayment of tax




– see Interest


Overpayment by employer of amount paid on account of sums deducted under PAYE

Overseas property purchase using borrowed funds

Paid by employer, Class 1 exclusion

Partner payment notices


– see Partnership

Partnership return


– see Partnerships


– see PAYE

PAYE implications of moving overseas


Payment apportioned over period calculated

Payment by former employer to retired employee on termination by compromise agreement of membership of employer's private healthcare scheme

Payment constitute 'yearly interest'

Payment for exit lease

Payment made at time of acquisition described as goodwill

Payment made by cheque

Payment made not a capital receipt but an emolument from employment

Payment of tax

– see also PAYE; Payment of tax


Payment taxable as a single payment in tax year received

Payment to third party

Payments made to directors as dividends, erroneously paid as remuneration

Payments out of a trust

Payments received from overseas

Payments subject to tax as general earnings within ITEPA 2003, s. 62

Payments subject to tax under ITEPA 2003, s. 401

Payments to beneficiaries, timing of

Pecuniary legacies


– see Penalties

Penalty provisions 2020-21

Deliberate default

Errors in returns

False statements

General anti-abuse rule

Incorrect returns or accounts

Information notices, inaccuracies/failures to comply with

Late returns

Notification of chargeability, failure to notify

Offshore assets/income/activities and tax evasion

Records, failure to keep and retain

Tax avoidance schemes

Pension death benefits

Pension fund

Income and Corporation Taxes Act 1988, Sch. 23A

Manufactured overseas dividends

Restriction on movement of capital

Treaty Establishing the European Community, art. 56

Pension income

Pension scheme of former employer, eligible for relief from UK income tax

Pension scheme sanction charges

Scheme administrator appealing under Finance Act 2004, s. 269 against HMRC's decision

Unauthorised payments charge under Finance Act 2004, s. 208

Unauthorised payments surcharge under Finance Act 2004, s. 209

Pension schemes

Pension special annual allowance charge (2010-11)


Alignment of pension input periods with tax years

Annual allowance


Late notification of claim for enhanced protection

Reasonable excuse

Some lump sum death benefits taxed

Special lump sum death benefits charge

Unauthorised payments

Periods prior to death


Filing of return

Issuing of return

Late payment

Payment of tax

Penalties, incorrect returns and errors

Penalties, late payment

Penalties, late return

Rates of tax

Repayment interest

Permission to give late notice of appeal

Personal allowances

Personal allowances and reliefs

Personal injury trust

Personal reliefs

Personal tax accounts

Personal tax returns submitted late

Post-death restructuring

Postponement of tax applications


Non-compliance with directions

Onus of proof

Potential lost revenue

Pre-death versus post-death periods

Pre-existing option arrangements

Preliminary issue

Appellant resident in South Africa


Income taxable as business profits under South Africa/UK Double Tax Treaty 2002, art. 7

Income taxable as employment income under South Africa/UK Double Tax Treaty 2002, art. 14

Interpretation of Double Tax Treaty in accordance with the Vienna Convention on the Law of Treaties

Performance of duties of employed diver in UK waters treated as the carrying on of a trade in the UK

Presumption of continuity


Adjournment and directions for preliminary hearing on issues of principle

Admissibility of expert evidence report

Appeal against determinations issued on basis that appellant domiciled in England and Wales

Appeal against HMRC decision on statutory sick pay

Appeal struck out


Appeals to be admitted out of time due to mental illness

Appellants' unsupported application to amend Grounds of Appeal

Application by a non-party to the proceedings to provide witness evidence

Application for admission of late appeal

Application for admission of late application for permission to appeal

Application for closure notice

Application for disclosure of HMRC policy documents

Application for hearing in private

Application for late appeal

Application for permission to notify a late appeal

Application for preliminary hearing

Application for reinstatement

Application for summons to be set aside

Application to amend decision

Application to lift stay directions issued following the dismissal of the lead appellants' appeals

Application to make appeal out of time

Application to postpone hearing

Application to reinstate appeals that had been withdrawn

Application to set aside not within Tribunal Procedure (First-tier Tribunal)

Application to set aside strike out under Tribunal Procedure (First-tier Tribunal)

Application to strike out under Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, r. 8(2)(a), 8(3)(a)

Application to submit additional documents

Applications for costs by appellants and respondents

Discovery and penalty assessments

Effect of TMA 1970, s. 54 agreement

Employee affected joined as second respondent to the appeal

Established that appellant does not dispute entitlement to SSP

Extent and effect of restriction

Factors relevant to application, overriding objective

Guidance on 'necessary expenses of attendance'

HMRC administration and behaviour

Income tax appeal

Insufficient tax deducted via PAYE

Jurisdiction of tribunal

Lack of action following further correspondence leading to unless order

Lodging of appeal following correspondence with HMRC's complaints service

Non-appearance of appellant

Non-compliance with directions

Penalty imposed in accordance with Finance Act 2008, Sch. 36, para. 50

Permission to appeal Construction Industry Scheme penalty out of time

Permission to appeal given by First-tier Tribunal

Permission to notify appeal to tribunal out of time

Reasons for making application and for any delay

Reinstate appeals

Respondents' application to amend Statement of Case

Statutory restriction on right of appeal

Strike out application

Tribunal had jurisdiction to issue summon

Tribunal has jurisdiction to allow application

Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (SI 2009/273), r. 8(2)(a)

Tribunal's decision after r. 17 withdrawal

Tribunal's jurisdiction over late payment interest charged

Upper Tribunal decided not to set aside its extension of time decision

Upper Tribunal disclosing appeal documents to a third party

Upper Tribunal refused to suspend penalties for the failure to comply with information notices

Upper Tribunal remitting case to FTT for fresh hearing

Upper Tribunal setting aside decision of FTT on appeal by HMRC

Upper Tribunal struck out appeal against FTT decision on information notice

Withdrawal of case under Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, r. 17 in default paper case

Witness summons issued

Proceeds of Crime Act 2002 ('POCA 2002')

Profit on disposal of 'stripped' corporate bond treated as discount

Property income

– see also Property income


Provisional collection

Provisional taxation

Purchase of business-concerns over means of purchaser-information requested

Information requested reasonably required to establish appellant's tax position

Purchase of properties by pension scheme

Residential property

Taxable property

Purchase price of stripped note and redemption value a 'discount', difference between

Qualifying conditions met for NCA to make assessments


Ramsay approach


Rates and allowances

Rates of tax

Before death

During administration period


Reasonable excuse

Late submission of return

Late submission of self-assessment tax returns

Non-appearance of appellant

Reasonable grounds for not issuing closure notice

Recommended medical treatment


Recovery of debts by HMRC

Redundancy payments

Refund of widows and orphans contributions

Registered pension schemes

Funds invested at member's direction in preference shares of finance company

Payments not registered transfers but unauthorised member payments

Registration requirement for trusts

Relationship between enquiry and disclosure

Contemporaneous closure of enquiry

Discovery requires new information of fact or law

Insufficiency of assessment

Validity of assessment

Reliance on agent

Relief for bad debts

Relief for error or mistake

Relief for gifts to charities

Arrangement designed to enhance relief or create artificial tax losses

Basis of valuation to be adopted

Determination of market value


Impact on value of listed shares

Market value of shares on initial listing

Relevance of market transactions on first day of listing

Relief for loan interest

Buy interest in close company

Interest in employee-controlled company

Relocation benefits

No change in residence due to cessation of employment

Relocation costs

Remission of tax, HMRC's delay in using information

Remittances home

Removal of referendum requirement

Remuneration trust

Rent-a-room relief

Rental income

Rental income, basis of assessment


Repayment claims

Repayment supplement


Reporting the death

Representative capacity, persons chargeable in

Bodies of persons

Personal representatives


Residence status of PRs

Residential property businesses


Residuary legacies

Respondent, non-UK resident in 2005/06 tax year

Restricted securities

Restrictions on remittance basis

Retention of respondent's home in UK

Returning to the UK


– see Returns

Right of personal representatives to make a claim after the deceased's death


Sales of occupational income

Savings income


Schedular system (to 5 April 2005)

Scheme funds invested at scheme member's direction in preference shares of finance company

Scheme sanction charges

Scheme administrator reasonably believed that no unauthorised payment was being made

Scottish Parliament

– see Scotland

Scottish rates

Scottish taxpayers


Security for payment of PAYE


Self-assessment tax return

Self-employed flying instructor with office at home

Amounts assessed in relation to telephone expenses, excessive

Deductibility of travel expenses and telephone expenses

Disallowance of travel cost between home and two airfields

Discovery assessments properly made

Travel expenses incurred wholly and exclusively for purposes of self-employment

Self-employed income

Self-employment and employment distinguished

Set-off of losses

Settlor-interested trusts

Share loss relief

Share options

Shares in qualifying trading company

Special circumstances, meaning

Status of worker

Strike out application

Strike out application for late appeal

Strike out, appeal facts identical to case appealed by husband


Sufficient records delivered

Supplementary decision

Tax avoidance scheme

Acquisition of shares and not money by employees

Capital allowances

Distribution of profit to members of an LLP

Dividends excluded from computation of income of partnership for tax purposes giving rise to a loss

Gifts to charity relief

Isle of Man double taxation arrangements

Partnership purchasing rights to dividends and receiving dividends

Partnership trading in short-dated securities

Payment of dividends on shares thereon to employees

Payment of manufactured overseas dividends

Provision of motor cars to members of the LLP

Purchase of dividend rights and receipt of dividends, transactions in the course of trade


Tax charged on value of assets before date from which withdrawal of approval took effect

Tax compensation payment as part of foreign pension exempt from UK tax

Tax due on interest received, delayed payment of monies due under critical illness policy

Tax rates








Savings and dividend income


Trust, dividend trust

Tax treatment of other expenses and capital expenditure

Taxability of payments to 'whistle blower' pursuant to order for interim relief under Employment Rights Act 1996, s. 129

Taxable income

Taxation of overseas dividends received by resident beneficiary of non-resident trust

Taxi driver

Taxpayer carried on a trade commercial with a view to profit

Taxpayer employed in drainage and sewage industry

Taxpayer notice

Taxpayer's appeal against 3 inaccuracy penalties

Temporary non-residence

Termination of employment

Appellant claimed that payment made by employer not taxable, settle discrimination case

Compromise agreement signed after termination and payment of £200,000


Payment received in connection with termination of employment within ITEPA 2003, s. 401

Payment within ITEPA 2003, Pt. 6, Ch. 3 and chargeable to income tax

Receipt of cash and shares under Compromise Agreement

Termination payments

– see also Termination payments


Timing of tax charge

Total income


– see Deductions

Outgoings eligible for relief

Trade or business

Trades carried on a commercial basis (Income and Corporation Taxes Act 1988)

Trading income

Transfer of trade as going concern

Transferable marriage allowance

Transferee liable for delibarate inaccuracies of transferor

Transport workers

Travel and relocation costs

Travel expenses

Deductible to Income Tax (Earnings and Pensions) Act 2003, s. 338

Expenses incurred wholly and exclusively for purposes of self-employment

Self-employed consultant anaesthetist in private practice making journeys from home to hospitals where professional duties are carried out

Travel expenses of members of local authorities


Treated as paid

Treatment of agency workers

Treatment pf unidentified receipts as taxable income

Tribunal's discretion exercised to refuse an extension in the light of overriding objective of the Tribunal's rules

Tribunal's jurisdiction over mitigation


– see Trustees

Trustees, liability for tax

– see Trustees


– see Trusts

Trusts other than absolute trusts

UK main rates

Additional rate

Basic rate

Higher rate

Scottish rate

Welsh rate

UK-US Double Tax Agreement (SI 2002/2848), art. 17

Unauthorised payment charge

Undeclared income


Underdeclaration of takings

Underpayment caused by employer collecting and accounting for tax at basic rate

Understatement of income

Understatement of sales and rental income, deliberate

Unexplained income


– see also Recovery of tax


– see Interest


Unpaid, recovery

Use of company assets by directors

Value added tax

Assessments on undeclared overseas interest

Assessments on unexplained deposits in overseas bank account

Associated penalties

Previous decision in principle allowing the appeals in part

Repayment of output tax accounted for but not properly due

Valueless shares acquired by taxpayer

Venture capital trust

Welsh rates

Additional rates


Commencement of income tax provisions, referendum


Implementation and operation, reports

Income tax provision, commencement

Power to make provision

Referendum by assembly, proposal

Removal of referendum requirement

Social security

Welsh taxpayers

– see Welsh taxes

Withdrawal of relief under enterprise investment scheme