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In David Andreae v HMRC [2022] TC08473, the First Tier Tribunal (FTT) allowed appeals against Follower Notice penalties. It was reasonable given the circumstances that the taxpayer did not take corrective action within the time limits. They had actively sought and relied on advice from the promoter and sought a second opinion once confidence in the promoter had been lost.

The FTT allowed the appeal finding that:

Useful guides on this topic

Accelerated Payments & Follower Notices
What are Accelerated Payments and Follower notices? What action is required? What are the penalties for non-compliance? Is there a right to appeal?

Disguised remuneration loan charge
What is disguised remuneration? What is the loan charge? When does the loan charge apply? Will the loan charge affect me?

How to appeal a tax penalty (subscriber version)
What are the steps in making an appeal? What should your appeal cover? What does recent case law say on this topic?

External links

David Andreae v HMRC [2022] TC08473


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