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Advice is given on the powers of HMRC to extend an informal enquiry into a company’s affairs to the personal tax returns of a director
During an informal enquiry into a limited trading company’s corporation tax affairs the director’s personal bank statements were requested. This was refused on the grounds that those records were not relevant to the company.
The inspector opened a TMA 1970 s 9A enquiry into the director’s 2012/13 self-assessment tax return and then asked for the source of the capital introduced into the company’s accounts in April 2011 and March 2012.
We argued that those dates were outside the scope of the inspector’s s 9A enquiry to which the inspector replied he was basing his request on the powers to request information contained in FA 2008 Sch 36 para 64(1). Schedule 36 was not mentioned in the opening letter so does that mean that the inspector has made a valid Sch 36 information request?
Do we need to comply with the inspector’s request?
Query 18 312...
