An appeal against high-income child benefit charge assessments was dismissed, but an appeal against a penalty for late notification of liability to the charge was allowed on the basis of reasonable excuse after the taxpayer did not receive HMRC’s ‘nudge’ letter. 

The appellant claimed child benefit for three children in January 1997, June 2005, and July 2012. Up to and including the tax year 2019/20, the appellant was an employee and was not within the self-assessment regime, so she received no tax return filing notices. In 2012, prior to the introduction of the high-income child benefit charge (HICBC), HM Revenue and Customs (HMRC) issued several press releases, which detailed the introduction of the charge and advised affected individuals to register for self-assessment. Further press releases were published in 2014, 2018, and 2019. 

The appellant’s adjusted net income for 2018/19 and 2019/20 each exceeded £50