What is a reasonable excuse?

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The Upper Tier Tax decision in Perrin provides a detailed explanation of the concept of a reasonable excuse.

At 20 pages it is not the longest decision; and is worth a read if you or a client wishes to appeal an HMRC decision on reasonable excuse grounds.

Towards the end of the decision there are three important details:

-        What are the facts? What evidence exists for those facts (para 81)?

-        Ignorance of the law is usually no excuse (para 82).

-        HMRC’s oft-quoted phrase that a reasonable excuse has to be based on ‘unforeseeable or inescapable’ circumstances is highlighted as a faulty argument.

Here is the full decision: http://www.bailii.org/uk/cases/UKUT/TCC/2018/156.html 

About Les Howard


Hi, I am a VAT Consultant, working mainly with charities. I am based in Cambridgeshire

I have over 20 years experience in VAT, and am currently also a part-time member of the Tax Tribunals.


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12th Nov 2018 10:18

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