Priory London Limited v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v Jocoguma Properties Limited [2022] UKUT 00225 (TCC)

JurisdictionUK Non-devolved
JudgeMr Justice Zacaroli,Judge Ramshaw
Neutral Citation[2022] UKUT 00225 (TCC)
Subject Matter12 August 2022
CourtUpper Tribunal (Tax and Chancery Chamber)
Published date18 August 2022
UT Neutral citation number: [2022] UKUT 00225 (TCC)
UT (Tax & Chancery) Case Numbers: UT-2021-000104 UT-2021-000199
Upper Tribunal
(Tax and Chancery Chamber)
Hearing venue: The Rolls Building, Fetter Lane, London EC4A 1NL
Heard on: 12 July 2022
Judgment date: 12 August 2022
Annual Tax on Enveloped Dwellings - Late filing of returns - Daily Penalties - Paragraph 4 of
Schedule 55 to Finance Act 2009 Paragraph 4(3) provides that the date specified in a notice
under paragraph 4(1)(c) from which a daily penalty is payable can be prior to the date the notice
is issued. HMRC appeal allowed.
Before
MR JUSTICE ZACAROLI
JUDGE PHYLLIS RAMSHAW
Between
PRIORY LONDON LIMITED
Appellant and
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS
Respondents
-and-
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS
Appellants and
JOCOGUMA PROPERTIES LTD
Respondent

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