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J Yerou and another v HMRC

In J Yerou and another v HMRC [2022] UKFTT 79 (TC) (23 February 2022) the FTT held that on the facts of the case HMRC’s information notices were not reasonably required. The parties were unlikely to agree the tax position even if the requested information was provided before tribunal proceedings were underway.

Here the taxpayers a married couple were shareholders in a UK company. In July 2012 they transferred B shares to the husband’s father who was resident overseas. He received dividends from the shares. He made loans to the couple and paid towards their children’s school fees.

After an enquiry HMRC issued discovery assessments on the basis that the transfer of assets abroad or settlements provisions applied so that the dividends were taxable on the taxpayers.

HMRC also sent the taxpayers a FA 2008 Sch 36 information notice requesting statements for UK and overseas...

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