Assessment of amounts due by way of penalty

Generally

Time limits and supplementary assessments

Claim statute-barred

Company buyback scheme, compensation for negligent advice

Compensation, capital or trading receipt

Domicile status of client

Income tax self-assessment return, undisclosed profits

Incorrect information, penalties

Loss of tax due to

National Insurance contributions, non-payment by limited company

Partnership records

Penalties

Mitigation

Restriction of deductions for direct tax purposes

Penalties for

– see Penalties

Penalties for offences

Relevance of concept re careless conduct

Returns and accounts, penalties

Failure of appeal against amount

Generally

Maximum award not excessive

Reduction of maximum penalties

Tax advice

Claimant resident but not ordinarily resident in UK for tax purposes

Company buyback scheme

Generally

Tax avoidance scheme, clearance revoked