Brantjes v HMRC

In Brantjes v HMRC [2020] UKFTT 177 (TC) (7 April 2020) the FTT broadly upheld information notices and penalties for failure to comply with them.

The taxpayer appealed against two information notices issued under FA 2008 Sch 36 and against a fixed penalty and daily penalties in respect of each notice. She contended that the notices were deficient in ten different ways and that therefore the FTT should set them aside.

The FTT considered each of the alleged deficiencies in turn and concluded that the notices should not be set aside but varied in respect of certain of the deficiencies. It decided that the requirement in one of the notices to provide the names of any cohabitees of the taxpayer was unlikely to assist in assessing her tax position and so was unreasonable and should be removed. Two requirements to provide documents stretching back 20 years were to...

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