An honest belief by the appellant company’s director that he was not required to file an ATED return for property purchased through the appellant, and the illness of the director, did not amount to a reasonable excuse for failing to file ATED returns by the statutory due date, and no special circumstances applied. 

The appellant purchased an apartment in 2014. The appellant’s director became ill in January 2016. He later realised that he should have appointed an accountant and instructed one in 2022, after receiving a letter from HM Revenue and Customs (HMRC)concerning corporation tax. The appellant was late in submitting annual tax on enveloped dwellings (ATED) returns, and HMRC imposed penalties in respect of the years ended 31 March 2017 to 31 March 2023 (inclusive). The