Income tax

The taxpayer had engaged specialist advisers to deal with his pensions but in the event, his notification seeking enhanced protection had been made late to the Revenue and Customs Commissioners, and was rejected.

On appeal, the First-tier Tribunal (Tax Chamber) dismissed the taxpayer’s appeal, deciding that although he had had a reasonable excuse for failing to apply for enhanced protection prior to the closing date, as required by reg 12(b) of the Registered Pension Schemes (Enhanced Lifetime Allowance) Regulations 2006 (SI 2006/131), he had not given the notification without unreasonable delay after the reasonable excuse had ceased, as required by reg 12(c) of those regulations.