The appellant did not have a reasonable excuse for the late filing of its annual tax on enveloped dwellings return, but its appeal against daily filing penalties was allowed as HMRC were late in notifying the penalties.  

The appellant was liable to file an annual tax on enveloped dwellings (ATED) return for the year to 31 March 2019. This was the first ATED return due to be filed by the appellant. The filing deadline was 30 April 2018.  

The appellant was unaware of its obligation to file an ATED return and did not file a return by the 30 April 2018 deadline. In March 2019, the appellant’s accountant made the appellant aware of its filing requirement. On 28 March 2019 (i.e. almost eleven months late), HM Revenue and Customs (HMRC) received the appellant’s ATED return. No tax was due under the ATED return. 

An