Appeals and reasonable excuse

A taxpayer’s inability to meet an obligation such as a payment or filing deadline due to coronavirus (COVID-19) will be accepted as a reasonable excuse. However, this is on condition that the taxpayer remedies the failure as soon as they are able to do so. Additionally, taxpayers will need to explain how they were affected by coronavirus when making their appeal, and this is discussed in 'Covid-19 and reasonable excuse' by Helen Adams in Tax Journal, Issue 1489, 12 (29 May 2020).

Further time is also being given to seek a review of, or appeal against, an HMRC decision. An extra three months is provided to appeal any decision that is dated February 2020 or later. However, appeals should be submitted as soon as possible, and they should include an explanation that the delay is due to coronavirus.

HMRC will also not object if, because of coronavirus, an application is made to the tribunal to hear a late appeal, provided that:

  • the review decision is dated February 2020 or later, and
  • the application is made within three months of the normal deadline

The guidance on the GOV.UK website has now been updated to reflect the above. See Tax Tribunals for more detail on appeals.