Application for approval of third-party information notice

17 December 2018

Issue: 4677 / Categories: Tax cases

CRC ex parte a taxpayer (TC6710)

The taxpayers several UK resident companies were members of a group. The statutory auditor delivered a qualified audit opinion on an accounting period for which it could not be certain of the correct amount to include in the taxpayers’ statutory accounts for intra-group debtor balances. Further it could not be certain that turnover had been correctly stated in the relevant accounting period or the previous one. The auditor also prepared and submitted the taxpayers’ corporation tax accounts as the agent.

HMRC applied for an information notice under FA 2008 Sch 36 para 3 requiring the auditor to provide for each of the taxpayers information on the checks it had used to verify intra-group debtor balances and copies of its working papers relating to them. Also it asked for details of how it had verified turnover and copies of relevant working papers.

The issue was whether...

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