Income tax

The First-tier Tribunal (Tax Chamber) (the FTT) allowed the taxpayer’s appeal against a decision of the Revenue and Customs Commissioners to the effect that he had not had a reasonable excuse for submitting a late application for enhanced protection in respect of a lifetime allowance charge pursuant to para 12 of Sch 36 to the Finance Act 2004. The FTT held that, as required by reg 12 of the Registered Pension Schemes (Enhanced Lifetime Allowance) Regulations 2006 (SI 2006/131), the taxpayer had had a reasonable excuse for not giving the required notification on or after the relevant closing date, and had acted without unreasonable delay once he had discovered that no notification had been made on his behalf.