TelNG v HMRC

Cathya Djanogly

In TelNG v HMRC [2016] UKUT 363 (12 August 2016) the UT found that an information notice requiring documents to be sent to HMRC (without indicating a place for production) was valid.

TelNG was applying against an information notice (FA 2008 Sch 36) on the grounds that Sch 36 required the documents to be produced at a place (para 7(2)); and instead HMRC had required the documents to be sent either by post or by email.

The UT observed that a notice is incomplete if it fails to provide a means for compliance with the requirement for the provision of information or the production of documents itself. However para 7(2) should be construed ‘purposively and in its wider context’ and could not be read as providing the only permissible means for the production of documents generally. The UT noted that a requirement to send documents by email...

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