To make things easier for agents representing individuals and businesses whose 2019/20 self-assessment return is filed after 28 February 2021, HMRC has developed a new process for agents to submit bulk appeals for late filing penalties on behalf of their clients where COVID-19 is being claimed as a reasonable excuse.

We understand from a recent meeting with HMRC that 2019/20 late filing penalties began to issue mid-March to anyone who’s return was not filed by 28 February 2021.

This route for bulk agent appeals for late filing penalties opened from Wednesday 24 March 2021 and is available for a period of six months. Bulk appeals can be made in batches of 25 and each appeal must be recorded using the template provided by HMRC which, on completion, must be sent to the following address: Bulk Agent Appeals, HM Revenue and Customs, BX9 1ZH.

Any appeals for a High Net Worth Unit taxpayer should be submitted via the normal route and should not be included on a bulk appeals template.

The template must only be used for 25 or less 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 less clients. If you complete multiple templates, these should be sent in separate envelopes.

All fields on the template should be completed – without this, HMRC won’t process the appeal for that client. The 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 (using either the SA370 or filed online).

HMRC have made clear that they reserve 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.