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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Publishing details of deliberate tax defaulters: publication: when does a qualifying relevant penalty become final - example 1 - penalty assessment


Two qualifying relevant penalties, see CH190700, arise from a compliance check into Georgina’s VAT returns. One relates to the tax period 09/13 and has a qualifying PLR, see CH190720, of £17,000 and one relates to the tax period 03/14 with a qualifying PLR of £18,000. We issue penalty assessments on 1 October 2014.

Tax period 09/13 - Georgina does not appeal against this penalty assessment. The qualifying relevant penalty becomes final on 31 October 2014. This is the day after the 30-day appeal period expires.

Of course, if Georgina makes an application for a late appeal after 31 October 2014, and we accept her application, the penalty will become final when the appeal is finally determined.

At 31 October 2014, the qualifying PLR is £17,000.

Tax period 03/14 - Georgina appeals against this assessment. The tribunal hears the appeal on 20 April 2015 and finds against Georgina at the hearing. Georgina applies for permission to appeal to the Upper Tribunal. The tribunal refuses permission on 4 June 2015. The qualifying relevant penalty becomes final on 4 June 2015.

On 4 June 2015, the qualifying PLR becomes £35,000.