Informal enquiries by HMRC

In JJ Management Consulting LLP v HMRC [2020] EWCA Civ 784, the Court of Appeal confirmed that HMRC can gather information for the purpose of an informal enquiry into an individual’s tax affairs, and do not need to use the legislation in section 9A TMA 1970.

The taxpayer Brian Robertson was a UK resident and domiciled individual, operating supermarkets in Spain and Portugal through five companies, two resident there, and three in the UK. HMRC suspected unreported income or gains, and issued schedule 36 FA 2008 information notices to Mr Robertson and third parties.