With regard to some of the comments made recently:
If E doesn't understand reasonable excuse, then he's far from alone. Show me ANYONE from HMRC who says they understand the concept of reasonable excuse and I'll show you a liar, a fool, or quite possibly both. Many, many tribunals have spent more time explaining to HMRC why they have failed to apply RE correctly, than they do rendering a judgment. Clearly, HMRC applies a different approach to different returns - and often the same type of return - all the time - and that is kind of E's point: a frankly risible lack of consistency.
People are regularly penalised for failing to account for tax where they didn't know they had an obligation to do so. That is also one of E's points. The fact that TENANTS are not so obliged under the NRL regime is simply reflective of a better, more reasonably crafted regime, created by a better, more reasonable tax authority.
The really concerning thing about some of these judgments is that they represent a tiny minority of cases. The vast majority will in all likelihood have been treated unfairly and poorly by the UK tax authority, safe in the knowledge that they are unlikely to be strongly represented because they are not usually UK nationals.
It seems eminently reasonable to me to infer that the ONLY reason for creating a regime which, as one of its greatest triumphs, requires a party to waste time notifying the UK authorities about something that they will be accounting for anyway, in due course through Self Assessment, is to generate revenue from penalties, from people who are innocent of a change in UK rules that was heralded on Twitter. A policy that HMRC is perfectly happy to take to tribunal to defend, even when it keeps losing (a bit like reasonable excuse). Which in turn tells you what you everything you need to know about the state and disposition of the UK tax authority in the 21st Century.