Scope of employee taxpayer information notice restricted.
In B Joseph v HMRC [2025] UKFTT 116 (TC) (3 February) the First-tier Tribunal (FTT) restricted the details which the taxpayer was obliged to give to HMRC under an information notice in a disguised remuneration case. Some personal information could be redacted and details of employment arrangements and supply chain were simplified.
HMRC sought information about the taxpayer’s employment with Alpha Republic Ltd (ARL) for 2020/21 as it considered that there could be disguised remuneration arrangements. Following informal enquiries HMRC issued a ‘taxpayer notice’ (under FA 2008 Sch 36 para 1 which requires that the information must be reasonably required for checking a taxpayer’s tax position).
The taxpayer objected to the information notice contending that it was too speculative and based on an unproven assertion that ARL had participated in avoidance arrangements and lodged an appeal...
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Scope of employee taxpayer information notice restricted.
In B Joseph v HMRC [2025] UKFTT 116 (TC) (3 February) the First-tier Tribunal (FTT) restricted the details which the taxpayer was obliged to give to HMRC under an information notice in a disguised remuneration case. Some personal information could be redacted and details of employment arrangements and supply chain were simplified.
HMRC sought information about the taxpayer’s employment with Alpha Republic Ltd (ARL) for 2020/21 as it considered that there could be disguised remuneration arrangements. Following informal enquiries HMRC issued a ‘taxpayer notice’ (under FA 2008 Sch 36 para 1 which requires that the information must be reasonably required for checking a taxpayer’s tax position).
The taxpayer objected to the information notice contending that it was too speculative and based on an unproven assertion that ARL had participated in avoidance arrangements and lodged an appeal...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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