Just wondered if you were aware that if you filed a Nil CIS return after the 19th due date and subsequently received the £100 late submission penalty then you can appeal this online and HMRC will agree the appeal and cancel the fixed penalty.
I had always been under the impression that if the return was late whether a Nil return or not then the penalty would be enforced unless a reasonable excuse could be proved but it seems that if no tax is due then HMRC will automatically cancel the penalty.
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Doug
These are only my opinions of how I see things and therefore should not be taken as advice