In JJ Management LLP & others v HMRC & another [2020] EWCA Civ 784 (22 June) the Court of Appeal found that HMRC is entitled to conduct informal investigations into a taxpayer’s affairs outside the normal statutory time limits where compliance with requests for information is entirely voluntary; and that judicial review into the conduct of such an informal investigation is likely to be in wholly exceptional circumstances.
R Hanan v HMRC [2020] UKUT 194 (22 June) concerns the time limit for issuing penalty notice within FA 2008 Sch 36 para 46. The Upper Tribunal decided that the question as to whether a penalty was issued within the para 46 time limits is to be determined in the light of the circumstances existing at the date of issue of that penalty.
In JJ Management LLP & others v HMRC & another [2020] EWCA Civ 784 (22 June) the Court of Appeal found that HMRC is entitled to conduct informal investigations into a taxpayer’s affairs outside the normal statutory time limits where compliance with requests for information is entirely voluntary; and that judicial review into the conduct of such an informal investigation is likely to be in wholly exceptional circumstances.
R Hanan v HMRC [2020] UKUT 194 (22 June) concerns the time limit for issuing penalty notice within FA 2008 Sch 36 para 46. The Upper Tribunal decided that the question as to whether a penalty was issued within the para 46 time limits is to be determined in the light of the circumstances existing at the date of issue of that penalty.
