Priory London Limited v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v Jocoguma Properties Limited [2022] UKUT 00225 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Zacaroli and Judge Ramshaw on 12 August 2022

Read full decision in Priory London Limited v HMRC and HMRC v Jocoguma Properties Limited UT-2021-000104 UT-2021-000199 Decision

Annual Tax on Enveloped Dwellings - Late filing of returns - Daily Penalties - Paragraph 4 of Schedule 55 to Finance Act 2009 – Paragraph 4(3) provides that the date specified in a notice under paragraph 4(1)(c) from which a daily penalty is payable can be prior to the date the notice is issued. HMRC appeal allowed.

Published 18 August 2022