The maximum of one point per month for two or more failures relating to the same submission obligation in the same month will not apply across different MTD for ITSA submission obligations. So, if an ITSA taxpayer has a quarterly regular update deadline, an End of Period Statement (EOPS) deadline and a Final Declaration deadline in the same month, they can accrue three points if they miss all three deadlines.
Where a taxpayer with MTD for ITSA submission obligations has two or more businesses (and is therefore required to submit separate regular updates and EOPS for each business), they will have one points total for all those submissions for different businesses. Where the taxpayer submits one or more of each of the different types of submissions late, they will only accrue a maximum of one point. For the purposes of this rule, tax year quarters will be used (rather than business accounting period quarters, which differ from business to business).
For example, if a taxpayer has three businesses and they fail to meet an ITSA regular update deadline falling in quarter 1 for either one, two or three of their businesses, they will accrue one point. If the same taxpayer fails to meet the EOPS deadline for either one, two or three of their businesses, they will accrue an additional point. If the same taxpayer fails to provide their Final Declaration by the deadline, they will accrue an additional point.
HMRC’s publication: Penalties for late submission