In Gold Nuts and others v HMRC [2016] UKFTT 82 (8 February 2016) the FTT decided preliminary issues relating to an appeal concerning a Code of Practice 9 (COP9) enquiry.
HMRC had informed Mr Budhdeo (both an appellant and a director of the appellant companies) that it was enquiring into his affairs under a COP9 which applies in cases where HMRC suspects fraud. HMRC had also opened enquiries into both the self-assessment (SA) returns and the corporation tax (CT) returns; and had issued FA 2008 Sch 36 notices as well as penalties for non-compliance with those notices.
Mr Budhdeo and the companies applied to the FTT asking it to order the closure of the COP9 enquiry and of the SA/CT enquiries and appealing against the Sch 36 notice and the related penalty. A preliminary hearing had taken place in February 2015 and this was a further preliminary...
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