The appellant and his wife (B) had their first child in November 2013 and a second child in 2015. B received child benefit in respect of one or both children during the tax years 2013/14 to 2015/16 inclusive. The appellant and B had separate bank accounts.  

Prior to HMRC sending him a letter raising questions about the high income child benefit charge (HICBC) in August 2017, the appellant was not aware that B was claiming child benefit; nor did he ask her if she was. The appellant’s adjusted net income for HICBC purposes exceeded £60,000 in each of the tax years. 

The appellant did not notify HMRC that he was chargeable to income tax for the tax years in question within six months of the end of those tax years or receive notice to file a tax return. HMRC sent the appellant a ‘standard’ letter about the HICBC on 17 August 2013 (although the appellant stated that he did not receive