In S Sangha v HMRC [2024] UKFTT 564 (TC) (27 June 2024) the FTT considered an appeal against an information notice issued by HMRC under FA 2008 Sch 36 setting aside some items in the notice and varied others.
HMRC opened enquiries into the taxpayer’s returns for 2015/16 and 2016/17 and in October 2021 HMRC issued an information notice. The notice sought information and documents in twelve categories. These included bank statements and accounts of a Hong Kong company of which the taxpayer had been a director; bank statements for a US account with Chase and details of any other overseas accounts; correspondence and information concerning a loan to the taxpayer used to invest in a company. The taxpayer appealed.
The FTT first considered whether any of the information and documents required by the notice were statutory records (for which there is no right of appeal). It held that they...
