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A without notice application for approval of a taxpayer notice under FA 2008 Sch 36 (para 1)

In A without notice application for approval of a taxpayer notice under FA 2008 Sch 36 (para 1) [2016] UKFTT 361 (24 May 2016) the FTT found that the taxpayer had not been entitled to a hearing and that HMRC had had jurisdiction even though the taxpayer had allegedly not been UK resident.

The taxpayer’s representatives had sought information with regard to the hearing of HMRC’s application for approval of an information notice under FA 2008 Sch 36. While acknowledging that the taxpayer would have no right to be represented at the hearing they asserted that the hearing should be a public hearing. HMRC had made a ‘without notice’ application under para 3(2A) and had applied for a direction that the hearing be in private on the ground that if the hearing were in public their case may be prejudiced.

The FTT observed that in such...

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