.png)
.png)
HMRC issued notices to the 14 petitioners under TMA 1970 s 20(1) requiring various documents and information from them in respect of their tax affairs.
The companies shared the same registered office directors company secretary and auditors and were all limited by guarantee. Eight were bond-issuing companies the others were trustee companies.
The inspector had written to each company saying that an investigation was to be carried out under code of practice 8 i.e. serious fraud was not suspected.
He had obtained the General Commissioners’ consent to issue the s 20(1) notices as the information required had not been provided.
The companies argued that there was no basis on which the General Commissioners who gave consent could reasonably have been satisfied that HMRC were justified in seeking that consent.
The Court of Session ruled that the companies’ complaints were not sufficiently relevant for the...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
