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The sides don’t seem evenly matched in investigation disputes between taxpayers and HMRC
KEY POINTS
- Do HMRC use FA 2008 Sch 36 powers to request information to which they are not entitled?
- Appeals against Sch 36 notices are often upheld.
- The threat of judicial review by the taxpayer may force a rethink by HMRC.
- Is the restriction to HMRC’s use of their power in Sch 36 para 19 commonly being ignored?
In July 2008 I was invited to speak at the ICAEW Wyman Debate on the then prospective powers being granted to HMRC and which were later enacted as FA 2008 Sch 36 (“information and inspection powers”). In the course of my argument I declared the information powers to be “the end of self assessment as we know it”.
You stupid boy
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