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How agents can appeal late-filing penalties in bulk


Published: 22 Mar 2021 Update History

HMRC has confirmed details of the temporary process which allows agents to submit an appeal against late-filing penalties on behalf of up to 25 clients.

HMRC has asked ICAEW’s Tax Faculty to share the following update with members:

Due to the impact of COVID-19 on individuals and businesses around the country, HMRC has not issued a late-filing penalty for anyone who has been unable to file their 2019/20 self assessment tax return by 31 January 2021 providing they did so by 28 February 2021.

HMRC recognises that due to the ongoing pandemic some customers and agents will still have difficulty meeting their filing obligations and has advised that COVID-19 may be accepted as a reasonable excuse for any appeals made against a late-filing penalty for self assessment customers.

To make things easier for agents representing these individuals and businesses, HMRC is introducing a route for agents to submit a bulk appeal for late-filing penalties, on behalf of their clients where COVID-19 is being claimed as a reasonable excuse for late filing of the 2019/20 self assessment return.

These appeals must be recorded using the appropriate template and sent to: Bulk Agent Appeals, HM Revenue and Customs, BX9 1ZH.

  • The template must only be used for 25 or fewer clients. If you need to submit an appeal on behalf of more than 25 clients, you should complete a second template.
  • Each envelope you return using the above address should contain no more than one template of 25 or fewer clients. If you complete multiple templates, these should be sent in separate envelopes (max 1 template per envelope).
  • All fields on the template should be completed – without this, HMRC won’t process the appeal for that client.
  • This template must only be used where the return was not filed by 28 February 2021 due to COVID-19. If the penalty is subject to appeal on other grounds, please use existing channels (see below).

Appeals can still be completed via the current method; this new route is for bulk appeals only. Appeals on behalf of one client should be filed using either the SA370 or filed online (online service is only available to taxpayers).

Please note that any appeals for a high-net-worth unit case should be submitted via the normal route and should not be included on the attached template.

This service is only for a COVID-19 related reasonable excuse. HMRC reserves the right to carry out random checks to ensure the validity of the data or to seek further clarification as to the exact nature of the COVID-19 related reasonable excuse.

This service will be available for a period of six months.

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