The taxpayer’s appeal against discovery assessments in respect of the high-income child benefit charge was dismissed, and ignorance of the law was not a reasonable excuse such that penalties for late notification of the charge were confirmed. 

The appellant was an employee within PAYE. In November 2010, the appellant's spouse claimed child benefit in respect of their first child. The appellant was registered for self-assessment from 2 August 2004 (he received rental income from an investment property). Tax returns were submitted for 2012/13 and 2013/14. The appellant declared his liability to the high-income child benefit charge (HICBC) in his tax return for 2013/14 and paid HICBC for that tax year. The investment property was sold in January 2014, and the appellant did not file tax returns for the tax years under appeal. The appellant returned to self-assessment for 2018/19 and declared his liability to HICBC for that year in his tax return.;<