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Too much information
Key points
- FA 2008 Sch 36 enables HMRC to issue information notices to taxpayers and third parties.
- Generally a return must be under enquiry before an information notice is issued.
- Is information requested under a third party notice protected by any type of privilege?
- Has there been a ‘watershed moment’?
- A Sch 36 notice can have extraterritorial effect without breaching international law.
- Be aware of the limits of information requests.
Taking effect from 1 April 2009 FA 2008 Sch 36 (‘Information and inspection powers’) provided HMRC with increased powers to obtain information and documents. At first this applied to income tax capital gains tax corporation tax PAYE the construction industry scheme and National Insurance contributions. A year later it was extended to other taxes and duties administered by the department. The schedule enables HMRC to request information or documents from taxpayers and third parties if this...
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