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AAA Oriental Ltd v HMRC

Sch 36 information notice upheld.

In AAA Oriental Ltd v HMRC [2025] UKFTT 69 (TC) (22 January) the First-tier Tribunal (FTT) dismissed an appeal against an information notice requiring the production of statutory records issued by HMRC under FA 2008 Sch 36. 

In 2023 HMRC began a compliance check into the company’s records for the year to 8 March 2023 to make sure it was meeting its obligations as an employer. In October 2023 HMRC issued a taxpayer information notice under Sch 36. The documents requested included mileage records directors’ loan accounts invoices including those for company credit card purchases a medical insurance policy and fuel card statements. The company appealed. 

The first issue for the FTT was the company’s argument that the notice was prohibited by Sch 36 para 21 which prevents a notice being given for the purpose of...

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