Qubic Tax Ltd v HMRC

In Qubic Tax Ltd v HMRC [2020] UKFTT 215 (TC) (11 May) the FTT dismissed various appeals made by four companies against data-holder notices under FA 2011 Sch 23 and information notices under FA 2008 Sch 36 but upheld an appeal against penalties for failure to comply with the information notices.

Qubic Tax Ltd appealed against two data-holder notices which required the provision of details of payments made by the company to third parties for the introduction of clients or potential clients. The FTT rejected the company’s argument that complying with the notices would be unduly onerous because they were too vague and difficult to understand. It also held that the explanation of the HMRC officer who conducted the formal review of the notices was sufficient to vary one of the notices and remove a particular ambiguity. The variation was within the scope of the...