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HMRC have powers, under Schedule 36 to FA 2008, to obtain information and documents from taxpayers and certain third parties. Those powers were extended by FA 2021, allowing HMRC to seek details from financial institutions (e.g. of a particular taxpayer’s credit card transactions).
All of these powers are subject to statutory constraints, and this book clearly explains both the extent of the HMRC powers and the associated safeguards, based on statutory provisions and numerous case law precedents.
The author encourages recipients of information notices to comply fully with requests that are within the law, but to recognise and stand up to those that are not. Professional advisers are reminded of the risks of providing more information than the law requires.
This edition is fully up to date, reflecting key decisions such as:
The new edition also contains new commentary to reflect HMRC’s revised approach to Alternative Dispute Resolution, and reflects developments in cases discussed in the previous edition (Embiricos and Sheiling Properties).