In JJ Management LLP & others v HMRC & another [2020] EWCA Civ 784 (22 June) the Court of Appeal found that HMRC is entitled to conduct informal investigations into a taxpayer’s affairs outside the normal statutory time limits where compliance with requests for information is entirely voluntary; and that judicial review into the conduct of such an informal investigation is likely to be in wholly exceptional circumstances.
R Hanan v HMRC [2020] UKUT 194 (22 June) concerns the time limit for issuing penalty notice within FA 2008 Sch 36 para 46. The Upper Tribunal decided that the question as to whether a penalty was issued within the para 46 time limits is to be determined in the light of the circumstances existing at the date of issue of that penalty.
In P Wilson...
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