Information notice under penalties for enablers of defeated tax avoidance legislation upheld
In Asset House Piccadilly Ltd v HMRC [2023] UKFTT 385 (TC) (19 April 2023) the FTT upheld the validity of an information notice to provide information under the legislation relating to penalties for enablers of defeated tax avoidance and rejected the appellant’s arguments that the demand for information made by the notice constituted an abuse of process and/or an infringement of the appellant’s right against self-incrimination.
In July 2021 HMRC issued a notice to provide information pursuant to Finance (No. 2) Act 2017 Sch 16 para 40 and FA 2008 Sch 36 to the appellant in connection with their suspicion that the appellant had been an enabler of abusive tax arrangements involving a remuneration trust with fiduciary receipt arrangements.
The appellant appealed the notice on the basis that:
HMRC’s characterisation of the appellant’s activities was incorrect and the appellant...
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Information notice under penalties for enablers of defeated tax avoidance legislation upheld
In Asset House Piccadilly Ltd v HMRC [2023] UKFTT 385 (TC) (19 April 2023) the FTT upheld the validity of an information notice to provide information under the legislation relating to penalties for enablers of defeated tax avoidance and rejected the appellant’s arguments that the demand for information made by the notice constituted an abuse of process and/or an infringement of the appellant’s right against self-incrimination.
In July 2021 HMRC issued a notice to provide information pursuant to Finance (No. 2) Act 2017 Sch 16 para 40 and FA 2008 Sch 36 to the appellant in connection with their suspicion that the appellant had been an enabler of abusive tax arrangements involving a remuneration trust with fiduciary receipt arrangements.
The appellant appealed the notice on the basis that:
HMRC’s characterisation of the appellant’s activities was incorrect and the appellant...
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