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No end to £1m penalty for ignoring stop notice
When most motorists come to a red light, they stop. However, some are happy to take their chances on running the lights and breaking the law.
This might be a reasonable analogy to use when considering the appeal made by Countrywide Partners Limited to the first tier tribunal against the penalty of £1m issued by HMRC under para 2(1) of schedule 35 of the Finance Act 2014 (Countrywide Partners Ltd vs HMRC, TC09810).
In common parlance, HMRC had issued a formal stop notice, in connection with the promotion of what they regarded as an ineffective tax avoidance scheme, which the company chose to accept but only to a limited extent.
A previous tribunal had already decided that HMRC legitimately issued a scheme reference number to counteract a contractor loan scheme. Later, Countrywide first asked HMRC to withdraw the stop notice then appealed against it but subsequently withdrew that appeal. Therefore, it was agreed that the stop notice was lawful.
