The taxpayer’s ignorance of his requirement to notify HMRC of liability to the high-income child benefit charge was a reasonable excuse for his failure to do so, and his appeal against a late notification penalty was allowed. 

The appellant’s income for the tax years 2018/19 and 2019/20 was £61,230 and £56,342, respectively. For both tax years, the appellant was an employee and outside the self-assessment regime. In December 2019, HM Revenue and Customs (HMRC) issued a ‘nudge’ letter, which was addressed to the appellant at 135 Ellesmere Road, Shrewsbury. The nudge letter explained HMRC wanted to help the taxpayer to understand whether he needed to pay the high-income child benefit charge (HICBC), the financial circumstances where a taxpayer might be liable to pay the charge, what to do next, and that if a taxpayer was not sure if they needed to pay the charge, the taxpayer should phone HMRC for assistance.