In HMRC v a taxpayer (ex parte) [2018] UKFTT 541 (10 September 2018) the FTT found that a company’s auditor who also prepared and filed its tax returns was protected from disclosure to HMRC by FA 2008 Sch 36 para 24.
The taxpayer was a company (‘Taxco’). Its auditor had delivered a qualified audit opinion stating that it could not be certain of the appropriate amount to include in Taxco’s statutory accounts in respect of intra-group debtor balances; and that for some companies of Taxco’s group it could not be certain that the turnover had been correctly stated. The auditor was also Taxco’s agent for corporation tax purposes and HMRC was concerned that Taxco’s tax liability depended on figures in its accounts that could have been understated. HMRC therefore applied for a third-party notice.
The FTT accepted that HMRC’s information request was reasonable. The main issue...
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