Bulk appeals for late-filing penalties for 2019/20 tax returns

A template for download is now available for bulk appeals


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 was unable to file their 2019/20 self-assessment tax return by 31‌‌‌ ‌January 2021 providing they did so by 28‌‌‌ ‌February 2021.

It is understood that around 1.1 million taxpayers failed to file their returns by 28 February 2021 and late filing penalty notices were expected to be issued to these taxpayers between 17 March and 24 March 2021.

HMRC has recognised that due to the ongoing pandemic some customers and agents will still have difficulty meeting their filing obligations and have 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 will be 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.

This route for bulk agent appeals for late filing penalties is available from 24‌‌‌ ‌March.

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

Points to note:

  • The template must only be used for 25 or fewer clients. If agents need to submit an appeal on behalf of more than 25 clients, they should complete a second template.
  • Each envelope returned using the above address should contain no more than one template of 25 or fewer clients. If multiple templates are completed, these should be sent in separate envelopes (maximum one 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, existing channels (see below) should be used instead.

Appeals can still be completed via the current method; this new route will be for bulk appeals only. Appeals on behalf of one client should be filed using either the SA370 or filed online.

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 and it is expected that 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 until September 2021.