Ignorance of the law was not a reasonable excuse for late notification of the high-income child benefit charge notwithstanding that two HMRC ‘nudge’ letters were not received, such that the penalties imposed were upheld.   

Prior to 2015/16, the appellant was not required to notify his liability to tax to HM Revenue and Customs (HMRC) or complete a self-assessment return. The appellant’s partner received child benefit in each of the tax years in question, having claimed child benefit for the first child in June 2015 and for the second in September 2018. In respect of each tax year in question, the appellant: (1) was not issued with a notice to file a tax return; (2) did not notify his liability to high-income child benefit charge (HICBC) to HMRC; and (3) did not file a tax return.  

On 17 May 2021, HMRC wrote to the appellant stating that they considered he was liable to HICBC for 2015/16 to 2019/20. The