Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Information about directors’ loan account

08 October 2019
Issue: 4716 / Categories: Tax cases

Matharu Delivery Service Ltd (TC7347)


HMRC opened an enquiry into the taxpayer’s corporation tax return. It issued FA 2008 Sch 36 para 1 notices to the taxpayer requesting details of the directors’ loan account. A copy of the loan account was sent to HMRC but it said the information was not the fully itemised chronological version requested. So it sent another Sch 36 notice this time to Mr M the owner of the taxpayer. It sent a similar notice in respect of his personal tax affairs. HMRC later imposed a penalty for failure to provide the information against which the taxpayer appealed.

The First-tier Tribunal said that when HMRC was inquiring into the tax affairs of a sole shareholder and his company information about the nature size and timings of payments between them was ‘reasonably required’ by the department. The judge accepted HMRC’s evidence that it was unable to...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon