“(1) A person is liable to a penalty under this paragraph if (and only if)– (a) The failure continues after the end of the period of 3 months beginning with the penalty date, (b) HMRC decide that such a penalty should be payable, and (c) HMRC give notice to the person specifying the date from which the penalty is payable.” (2) The penalty under this paragraph is£10 for each day that the failure continues during the period of 90 days beginning with the date specified in the notice given under sub-paragraph (1)(c). Paragraph 5 of Schedule 55 provides: A person is liable to a penalty under this paragraph if (and only if) - the failure continues after the end of the period of 6 months beginning with the penalty date. The penalty under this paragraph is the greater of – 5% of any liability to tax which would have been shown in the return in question, and£300 Paragraphs 6(1) and (5) of Schedule 55 provide: A person is liable to a penalty under this paragraph if (and only if) - the failure continues after the end of the period of 12 months beginning with the penalty date. ……the penalty under this paragraph is the greater of – i. 5% of any liability to tax which would have been shown in the return in question, and ii.£300 Paragraph 1 (3) of Schedule 55 states: “ (3) If P’s failure falls within more than one paragraph of this schedule P is liable to a penalty under each of those paragraphs (but this is subject to paragraph 17 (3))”
“(3) Where P is liable for a penalty under more than one paragraph of this Schedule which is determined by reference to a liability to tax, the aggregate of the amounts of those penalties must not exceed the relevant percentage of the liability to tax.”
“…….. there is a clear indication that the penalty should not exceed the amount liable to tax under paragraph 17. Mr. Long was on benefits part of the year and the latter part he started self-employment on a low income which made his tax liability nil. ………imposing these penalties is to encourage taxpayers to get their tax returns in on time, but surely if they have been on benefits part of the year and low income then£1,600 is excessive when no tax was due and puts a family such as Mr. Long under pressure……..”
“ Legal Submissions 3. Having had the opportunity to seek advice from policy on this matter, the Respondents respectfully submit as follows 4. The£300 penalties levied under both paragraphs 5(2)(b) and 6(5)(b) were not made by reference to tax liability and therefore paragraph 17 (3) is not engaged. 5. The penalty of£300 levied on the appellant under paragraph 5(2)(b) was in accordance with legislation. The penalty was imposed as the Appellant’s return was outstanding after the end of the period of 6 months beginning with the penalty date. 6. The penalty of£300 levied on the appellant under paragraph 6(5)(b) was in accordance with legislation. The penalty was imposed as the Appellant’s return was outstanding after the end of the period of 12 months beginning with the penalty date. 7. The appellant’s return for the tax year 2010/2011, which is not in dispute, shows he had no liability to tax. 8. In the circumstances, the penalties of£300.00 each made under the aforementioned provisions of Schedule 55, cannot be determined by reference to a tax liability as the appellant had no liability. 9. The minimum amount of penalty for a failure to file a return after 6 or 12 months is the greater of 5% of any liability to tax that would have been shown on the return, or£300 . If the liability is less than£6,000 *, the penalty is not determined by reference to tax liability but is£300 irrespective of the liability to tax. In this case, as the appellant had no tax liability for 2010/2011, he received penalties of£300 each under paragraphs 5(2)(b) and 6(5)(b). *The letter from HMRC states£600 but the Tribunal considers that this is an error and should read£6,000 10. Schedule 55 was introduced by Parliament to approve taxpayers’ compliance in the making and delivery of returns and documents to HMRC by the relevant due date. It was therefore Parliament’s intention to increase the penalty in relation to the length of time the return is outstanding. 11. If the legislation were to be interpreted in the way suggested, it would (appear) to be advantageous for a taxpayer with a nil liability to file his return later rather than sooner. For example, a taxpayer who filed his return 6 months after the penalty date would be liable to a penalty under 5 (2)(b) but not paragraph 6(5)(b). Therefore paragraph 17(3) could not be relevant on any reading because the taxpayer would only be liable to only one penalty. Whereas a taxpayer who filed 12 months after the penalty date would find the penalties imposed on him under paragraphs 5(2)(b) and 6(5)(b) could be reduced to nil under paragraph 17(3), as the aggregate amount of these penalties,£600 , would be more than his liability to tax. This result would be contrary to the spirit of the Schedule 55 penalty regime. 12. If there were a liability to tax, the penalty would be the greater of 5% of the liability, or£300 . The penalty does not take into account liabilities below a certain amount.”