In Parker Hannifin (GB) Ltd v HMRC [2023] UKFTT 971 (TC) (8 November 2023) the FTT held that an information notice which required the taxpayer company to carry out searches across its directors’ emails for specified terms was valid but that the requirement to disclose all of the resulting emails to HMRC was ‘far too wide’.
The background to this case involves a series of transactions within a corporate group structure to refinance a debt. As part of these arrangements the appellant company (PH) had issued a Eurobond and sought to deduct the interest in its tax computations. HMRC opened enquiries into PH’s corporation tax returns for the relevant tax years to establish whether the interest should be disallowed under the loan relationships unallowable purpose rule.
The central point in the decision surrounds an information notice issued by HMRC which required PH to carry out a search of emails...
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