Appeals against late notification penalties in respect of the high-income child benefit charge (HICBC) were allowed, as discovery assessments could not be used to assess the HICBC, so there was no ‘potential lost revenue’ on which penalties could be calculated.
The appellant’s wife was in receipt of child benefit. HM Revenue and Customs (HMRC) charged the appellant penalties for his failure to notify HMRC of his chargeability to tax for the tax years 2012/13, 2013/14 and 2014/15 in relation to the high-income child benefit charge (HICBC).
HMRC had issued ‘awareness letters’ in autumn 2012 to all taxpayers apparently in receipt of earnings in excess of £50,000. HMRC also issued letters (SA252) informing recipients who had any changes to their income in the last year or were affected by recent changes to child benefit for people on higher incomes, that they might need to complete a self
