HMRC v P Parissis (and related applications)

Alan Dolton

In HMRC v P Parissis (and related applications) (TC01083 – 20 April) HMRC issued notices under TMA 1970 s 20(1) requiring three settlors to provide various documents relating to the trusts they had established. They provided some of the information requested but failed to provide all the relevant information and HMRC applied for penalties.

The First-tier Tribunal imposed penalties of £200 on two of the settlors and imposed a penalty of £250 on the third settlor. Judge Mosedale observed that it was ‘improbable that a settlor would destroy such documents particularly in respect of a trust in which he and his close family are the only beneficiaries’.

Why it matters: TMA 1970 s 20 allows HMRC to issue a notice requiring a person to deliver documents which are in his ‘power or possession’. Where a settlor claims that he is...

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