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HMRC internal manual

Enquiry Manual

From
HM Revenue & Customs
Updated
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Penalties: Culpability - Defences: Failure to Make a Return - Unacceptable Reasons

The HMRC view is that reasonable excuse depends on some unexpected or unusual event that is either unforeseeable or beyond the taxpayer’s control, and which prevents the taxpayer from complying with their obligation.

The taxpayer has many months to complete their return. Even in pre-SA periods when there was a 30 day deadline, formal action was rarely commenced promptly.

You should therefore not accept as a reasonable excuse

  • the tax return is too difficult
  • my affairs are complicated
  • pressure of work
  • failure by the agent
  • delays in the post, unless there was an unforeseen event disrupting the postal service
  • insufficient records.