In One Call Insurance Services Ltd v HMRC [2022] UKFTT 184 (TC) (14 June 2022) the First-tier Tribunal (FTT) dismissed the taxpayer’s appeal against an information notice varying the terms of some of the items to be provided but otherwise confirming the notice because it found that the taxpayer did have de facto power to obtain the documents.
The dispute arose from a remuneration trust scheme entered into by the company. HMRC had issued PAYE determinations and NIC decisions in respect of contributions to and allocations made by the remuneration trust for several tax years and had opened enquiries into the company’s returns for those years. It then issued an information notice to the company requiring it to produce various documents and information. The company appealed but in fact provided some of the information; by the time of the hearing there were nine categories of information...
