This decision is a practical example of the FTT judge reconsidering his decision (which had already been published) to reduce the appellant’s follower notice penalties to 24% of the denied tax advantage. The judge reviewed his own decision under rule 41 of the FTT rules and remade it to restore the penalties to 42% of the denied advantage in the light of the Upper Tribunal’s decision in HMRC v Comtek Network Systems (UK) Limited [2021] UKUT 81 and the fact that the appellant only took corrective action after the date on which penalties were assessed.
Read the full decision here.
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