A US property millionaire will have to a penalty of £5,744,219 for a failure to file tax returns on time as Court of Appeal rules penalties were validly issued
The appeal by Peter Marano, a US citizen living in the UK during the relevant tax years, has been running through various tax tribunals since 2020 and relates to a tax dispute related to 2012-13.
Marano’s legal team had argued at various earlier tribunal hearings that he was not liable for the tax penalties and disputed the discovery assessment, arguing that they had been issued by HMRC in contravention of the relevant requirements in UK legislation.
At the Court of Appeal, the narrow question focused on whether section 103 Finance Act 2020 removes the need for the involvement of an HMRC officer in the process as long as the notice in question is a notice sent by HMRC.
