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Ignorance of the law by a foreign national was not a reasonable excuse for late tax return

By Mark McLaughlin, June 2025

A foreign national’s limited knowledge of the UK tax system, and complexities because of Covid and Brexit, did not constitute reasonable excuses for the late filing of his self-assessment return, and his appeal against late filing penalties was dismissed. 

The appellant signed up to receive paperless communications on 24 January 2022. HM Revenue and Customs (HMRC) issued a notice to file for the tax year ended 5 April 2022 via the appellant’s online personal tax account (PTA) on 6 April 2022. The appellant read the online PTA message but failed to submit his tax return for 2021/22 by the statutory deadline. HMRC imposed late filing penalties. The appellant appealed. The three initial issues for the First-tier Tribunal (FTT) were: (1) Was the appellant’s tax return for 2021/22 required to be made or delivered? (2) If so, were the penalties raised correctly? (3) If they were, was there a reasonable excuse and was the return filed without

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