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Man versus machine
Key points
- The Upper Tribunal has overturned lower tribunal decisions on notices to file self-assessment tax returns.
- What is the exact meaning of the words ‘by an officer of the board’ in TMA 1970 s 8(1)?
- It is not necessary that the notice should be issued by a ‘flesh and blood’ HMRC officer.
- It was important that HMRC officers had decided the criteria to identify taxpayers generally who should be sent notices to file.
- The Upper Tribunal provided guidance on how the First-tier Tribunal should deal with future concerns on s 8 notices.
Readers of Taxation may well have missed it among the new year festivities but at the very end of 2019 a decision of the Upper Tribunal was released that could have interesting implications for those seeking...
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