Priory London Limited v Revenue and Customs and Revenue and Customs v Jocoguma Properties Limited [2022] UKUT 225 (TCC) (12 August 2022)
Annual Tax on Enveloped Dwellings - Late filing of returns - Daily Penalties - Paragraph 4 of Schedule 55 to Finance Act 2009 - Paragraph 4(3) provides that the date specified in a notice under paragraph 4(1)(c) from which a daily penalty is payable can be prior to the date the notice is issued. HMRC appeal allowed.