The appellant’s failure to take corrective action in response to follower notices was not reasonable in all the circumstances, and follower notice penalties were upheld, albeit in reduced amounts. 

The appellant participated in a scheme promoted by tax consultants (M), which sought to exploit the UK/Isle of Man (IoM) double taxation arrangements by routing his earnings through an IoM partnership and an IoM trust. In his self-assessment returns for the tax years 2004/05 to 2007/08, the appellant declared income from the offshore trust and claimed an equivalent amount of double taxation relief. Following enquiries, HM Revenue and Customs (HMRC) concluded that additional income tax and National Insurance contributions (NICs) were due. The appellant appealed. In 2015, the decision in Huitson