The appellant’s appeal against late payment penalties was dismissed after he failed to reach agreement with HMRC over a ‘time to pay’ agreement, an insufficiency of funds due to existing financial commitments and circumstances were not attributable to events outside his control, and there was no reasonable excuse for late payment.
The appellant was a partner in a pan-European mid-market private equity firm. He was enrolled into self-assessment on 11 February 1999. The capital commitments of the appellant and his senior partners had been growing in tandem over time. On 30 January 2023, the appellant’s self-assessment return for the tax year 2021/22 was received by HM Revenue and Customs (HMRC). By the end of January 2023, &
