Tax Penalties and Behaviour Allegations

CTM advises on HMRC penalties, including challenges to behavioural categorisation and mitigation. We act where penalties materially increase exposure or where HMRC unfairly alleges careless or deliberate conduct.

Our Work Includes

• VAT and direct tax penalties
• challenges to deliberate behaviour findings
• reasonable excuse arguments
• suspension and mitigation
• Tribunal appeals

Approach

We assess:

• evidential basis for penalties
• correctness of HMRC behaviour findings
• proportionality and mitigation
• prospects of appeal success