In HMRC v AML Tax (UK) Ltd [2022] UKUT 81 (TC) (14 March 2022) the Upper Tribunal (UT) imposed a penalty of £150 000 on the company under FA 2008 Sch 36 para 50 for failing to comply with an information notice.
The company was part of an informal group of companies based in the Isle of Man and acted in relation to certain tax avoidance schemes utilised by UK contractors and sub-contractors. The precise ambit of its activities was unclear but included marketing of avoidance schemes on behalf of the group companies and design and implementation of at least one scheme. HMRC opened enquiries into the company’s returns for 2014 and 2015 and issued an information notice in February 2018. The company did not comply with the information notice at all until December 2019 and there was further non-compliance in relation to some items requested until August 2021....
