The appellant, David Barrett, submitted a late appeal to the tribunal regarding a liability to income tax payments totalling £2m relating to payment of royalties.
The case concerned whether Barrett’s accountants gave him the correct advice on meeting the time limits for appealing.
On 22 March 2019, HMRC gave Barrett a discovery assessment of £2,117,221.61 in relation to the tax year ending 5 April 2015.
In response, the tax authority sent a ‘view of the matter’ letter on 31 March 2021, declaring that it stood by the assessment and offered Barret to follow a statutory review.
The letter stated: ‘The statutory appeal period is 30 days from the date of this letter. However, in light of Covid-19, HMRC will not object to late appeals made to the tribunal where the appeal has been made within three months of the end of the 30-day appeal period.’
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