B Davies and others v HMRC

In B Davies and others v HMRC [2022] UKFTT 369 (TC) (10 October 2022) the FTT held that information notices issued by HMRC were not reasonably required to check the taxpayers’ tax position and directed HMRC to issue closure notices. The information requested was onerous and would have taken a long time to compile. Furthermore compliance with the information notice would not have necessarily given HMRC the information it actually required.    

HMRC opened an enquiry into the 2017/18 tax returns of Mr Davies and Ms Mahil a married couple operating a property investment business in partnership. Formal information notices were issued pursuant to FA 2008 Sch 36 seeking information and documents in relation to the financing of the taxpayers’ personal property and business portfolio since 2014 their bank statements for 2016/17 and any other sources of financing since...