No clear reason

Information notice requesting details from previous six years

HMRC carried out a VAT check on the taxpayer’s business a pub in July 2016. The officer requested a drinks price list but the taxpayer was unable to produce one. HMRC issued an information notice (FA 2008 Sch 36) in November asking for statutory records and other documents for the period 1 February 2012 to 30 April 2016.

The taxpayer appealed.

The First-tier Tribunal considered the period covered by the notice a key factor. The judge said if HMRC was requesting information for a period that exceeded four years it should explain why. In this case the Revenue’s response was that it usually asked for information over six years and failed to give any further reason. The tribunal was not satisfied with this saying HMRC should specify a reason and that it would expect there...