A couple of times I've responded to HMRC politely, along the lines of:
"it is, of course, difficult to explain to my client that their mistake potentially causes financial penalty when your letter itself contains a careless mistake"
and in both cases HMRC cancelled the penalty.
I had the same issue. It is being released in stages or on request. When requested they manually add it to your account to download via notifications.
This article may be useful
yes, but at 0.000000001%
I understand they have accepted some of his arguments.
Also see the article example with a large tax difference and the reasons (eg personal allowance).
See article Tim Good's article:
But, unlike the case link, with EBTs there are four transactions to consider,
not one? The taxpayer’s bad choice of using a tax scheme, the company settling funds, the trustees deciding to make a loan and the taxpayer accepting the terms of that loan.
Given the trustees hold a valuable asset for beneficiaries, which may include minors, surely the trustees would need to be a willing party to any claim for set aside, to protect their position?
If the transactions have not yet caused unexpected tax (eg HMRC out of time to go after employer, taxpayer doesn’t wish to settle) and the loan charge is a new tax that only hits if the loan is not repaid, where is the mistake to be set aside?
Appealing the gift to UKIP tax treatment seemed hopeless, even if the grounds are amusingly ironic.
For the later donations to the referendum campaign, I wonder if they’ll try arguing s10 IHTA (with s268), on the basis that the intention was effectively spending on leaflets and adverts?
Worth getting a lawyer to review your engagement letter, so there are no implied duties of care. But useful terms I’ve seen in such cirmumstances (to make it clear who is your client) are:
“If your own client wishes to rely on our advice they should engage us for the work themselves via a
separate engagement letter agreed with us and signed by them.
We will need to see your underlying client identification for work
relating to your clients before we begin the work.
Payment of our fees by you is not linked to how you may recharge these to your clients nor any delay
in your own fees being paid by your client. If our fees remain outstanding in relation to one of your clients, you agree that we may cease work relating to your other clients until those fees are paid.”
Get some proper tax and legal advice. You’re in danger of making mistakes, for which you may be personally liable, if you rely on the product provider, HMRC and forums.