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Imposing territorial limitations

24 January 2017 / Mary Ashley
Issue: 4584 / Categories: Comment & Analysis

The territorial limitations that might be imposed on FA 2008, Sch 36.


  • A taxpayer is granted judicial review of the tribunal’s approval of an information notice.
  • HMRC advised that the hearing would be in public.
  • In the event the First-tier Tribunal directed that the hearing be in private.
  • The fact that the taxpayer did not have a UK address was held not to restrict HMRC’s power here.

The territorial scope of Sch 36 was held to match the territorial scope of the liability to tax.

On 14 December 2016 the taxpayer was successful in his application for permission to judicially review the decision of Berner J in Re Revenue and Customs Commissioners’ Application (Without Notice Application for Approval of a...

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