A client who has been late with tax return submissions and operates under CIS, involves the repayment of tax.
Lateness of returns has lost any repayments over 4 years old (approx £1800) and late returns have suffered penalties.
My question is by accepting the penalties (which have been correctly applied) can I use the above sect of the act to ask HMRC to mitigate. Criterea appears to be financial hardship and disproportionality of penalties. Given he's a net recipient of tax the penalties are disproportionate and his recorded income over the last 4 years is approx £7.5k per annum - that appears to be low level of earnings.
If this can be done what is the approach