In the three years which have passed since HMRC’s new information powers were introduced, there has been surprisingly little judicial guidance on the meaning of the key criterion which HMRC must satisfy before these powers can be exercised.
In cases where HMRC seeks information or documents from a taxpayer or third party it needs to establish that the information is ‘reasonably required’ for the purpose of checking a taxpayer’s tax position (FA 2008 Sch 36 paras 1 2 and 5).
Taxpayers’ fears about the extensive reach of the new powers were confirmed early in their history when HMRC obtained third party notices against a number of financial institutions seeking information or documents on customers with UK addresses and non-UK bank accounts (Applications to serve a Notice under FA 2008 TC00148 & TC00149). Objections that the production requirement was too onerous and absence of serious prejudice to...
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In the three years which have passed since HMRC’s new information powers were introduced, there has been surprisingly little judicial guidance on the meaning of the key criterion which HMRC must satisfy before these powers can be exercised.
In cases where HMRC seeks information or documents from a taxpayer or third party it needs to establish that the information is ‘reasonably required’ for the purpose of checking a taxpayer’s tax position (FA 2008 Sch 36 paras 1 2 and 5).
Taxpayers’ fears about the extensive reach of the new powers were confirmed early in their history when HMRC obtained third party notices against a number of financial institutions seeking information or documents on customers with UK addresses and non-UK bank accounts (Applications to serve a Notice under FA 2008 TC00148 & TC00149). Objections that the production requirement was too onerous and absence of serious prejudice to...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
