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THIRD-PARTY-NOTICES


HMRC have formidable information gathering powers against which there are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at three common types of information notice and the extent to which they can be challenged.
Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.

HMRC is consulting on changes to the powers which it has to obtain documents from third parties, such as banks, when investigating somebody's tax affairs. The proposals have generated much adverse comment in the media because they would remove safeguards which currently exist to prevent HMRC from using its powers indiscriminately.

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