An annual tax on enveloped dwellings relief return was filed late and there was no reasonable excuse for the late filing, nor any special circumstances to merit a reduction in late filing penalties.  

The appellant purchased a property for £735,000 on 3 July 2018. The intention was to develop the property and provide affordable accommodation for young professionals. The filing date for the annual tax on enveloped dwellings (ATED) relief return for the period ending 31 March 2019 was 30 July 2018. An ATED filing was made on 25 February 2019 (i.e., 210 days late). On 29 November 2019, HM Revenue and Customs (HMRC) issued a notice of penalty assessment in the amount of £100, and on 10 January 2020 HMRC issued a notice of penalty assessment in the amount of £300 (both under FA 2009, Sch 55). The appellant appealed. 

The appellant argued: (1) HMRC’s guidance was unclear and misleading as to the filing deadline; the