Adam Craggs and Constantine Christofi (RPC) analyse the High Court decision concerning the jurisdiction of HMRC outside the UK.
The issue for the court to determine in Jimenez v (1) The First Tier Tax Tribunal & (2) HMRC [2017] EWHC 2585 (Admin) concerned the jurisdiction of HMRC to give a notice under FA 2008 Sch 36 to the claimant who lived in Dubai.
The claimant brought his challenge on the basis that HMRC’s information gathering powers do not have extraterritorial effect. In other words Mr Jimenez was arguing that as a non-resident living abroad he was not subject to the demand issued to him under the statute.
HMRC argued that the claimant was a taxpayer for the purposes of Sch 36 and that it has the power to give a notice under Sch 36 to any such taxpayer outside the UK principally to assist it to establish...
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Adam Craggs and Constantine Christofi (RPC) analyse the High Court decision concerning the jurisdiction of HMRC outside the UK.
The issue for the court to determine in Jimenez v (1) The First Tier Tax Tribunal & (2) HMRC [2017] EWHC 2585 (Admin) concerned the jurisdiction of HMRC to give a notice under FA 2008 Sch 36 to the claimant who lived in Dubai.
The claimant brought his challenge on the basis that HMRC’s information gathering powers do not have extraterritorial effect. In other words Mr Jimenez was arguing that as a non-resident living abroad he was not subject to the demand issued to him under the statute.
HMRC argued that the claimant was a taxpayer for the purposes of Sch 36 and that it has the power to give a notice under Sch 36 to any such taxpayer outside the UK principally to assist it to establish...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
