In Perfectos Printing Inks and others v HMRC [2019] UKFTT 388 (14 June 2019) the FTT directed that HMRC issue closure notices in relation to three related enquiries.
Dr Price was the main director and shareholder of Perfectos. An enquiry into his self-assessment tax return was opened and information notices were subsequently issued requesting bank statements which were provided. However HMRC considered that these were insufficient (as some lines were illegible and a day was missing) and they requested unredacted statements. The FTT observed that ‘the dividing line as to what was reasonably required when it came to the provision of personal bank statements lay between those cases where the officer could show a reason to suspect under-assessment and those where the officer was simply on a “fishing expedition”’. The tribunal could not see why HMRC required to know what Dr Price spent his money on...
