In PML Accounting v HMRC [2015] UKFTT 440 (10 September 2015) the FTT found that an information notice was invalid as it should have been issued as a third party notice.
HMRC had written to PML informing it that it was considering whether it was a managed service company (MSC) provider for the purpose of ITEPA 2003 Chap 9 Part 2. Having not obtained the information it required HMRC issued an information notice under FA 2008 Sch 36 on 26 November 2012. Following a delay caused by the director’s daughter suffering a serious accident some of the documents had eventually been sent to HMRC on 8 March 2013.
The FTT found that PML had provided all the information requested (even though it had then been asked to clarify certain points) but not all the documents. The first issue was therefore whether the director had a...
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