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HMRC’s stance on penalties

A recent hearing considered a long-standing issue – was a property sale an investment or trading activity?  It was held, in the company’s favour, to be an investment. But that, to a degree, is not important.

The interesting issue that emerged is that HMRC had sought to impose a penalty (of £1,000,000!) on the company on the grounds that it had been negligent in claiming investment treatment on the disposal.  The possibility that HMRC may contend that disagreeing with HMRC’s opinion is negligent behaviour deserving of a penalty is exceedingly concerning.



Date: 30th June, 2015
Author: Cathy Corns


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