- HMRC applied for penalties against Moir Management Services Ltd for failing to notify notifiable tax arrangements and not responding to a pre-disclosure enquiry.
- The Tribunal considered whether Moir was a “promoter” of notifiable arrangements, whether it failed its obligations, if it had a reasonable excuse, and the penalty amount.
- The burden of proof was on HMRC to show Moir was a promoter and failed to comply; Moir had to prove any reasonable excuse.
- The case was decided on the papers without a hearing, following procedural directions and an Unless Order regarding Moir’s case filings.
Source: bailii.org
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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