HMRC’s ‘nudge’ letters about the taxpayer’s potential high-income child benefit charge liability were sent to his previous address, which amounted to a reasonable excuse for the taxpayer’s late notification of the charge, and his appeal against penalties was allowed.  

The appellant’s partner (Mrs B) had received child benefit since November 2010. In the tax year 2018/19, she received child benefit for two children. From the time the high-income child benefit charge (HICBC) was introduced up to and including 2018/19, the appellant was not within the self-assessment regime. HM Revenue and Customs (HMRC) did not send him a notice to file a tax return (under TMA 1970, s 8); nor did he make a voluntary return (under TMA 1970, s 12D). 

The appellant’s adjusted net income in 2018/19 exceeded £50,000, which was higher than Mrs B’s. The appellant was required to notify HMRC of his