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Delays in obtaining trust deed from trustees was not a reasonable excuse

By Mark McLaughlin, October 2021

Delays by the appellant company in obtaining a trust deed from the trustees of a remuneration trust were not a reasonable excuse in an appeal against penalties for failing to comply with an information notice.  

HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s corporation tax returns for the years ended 31 December 2016 and 2017. HMRC also notified the appellant that it was conducting a compliance check of the company’s PAYE and National Insurance contributions position for those periods (plus the year ended 31 December 2015). This letter identified remuneration trusts as the areas being checked. 

HMRC informally requested information and documents from the appellant (via its agent), with a deadline of 6 July 2018. The appellant did not provide any of the information or documents in response to

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