Bank statements and an analysis of the contents of any overseas accounts from which a non-UK domiciled taxpayer made remittances to the UK in a tax year were ‘reasonably required’ by HMRC to check the taxpayer’s tax position.
HM Revenue & Customs (HMRC) opened an enquiry into the appellant's tax return for 2009/10. Following correspondence between HMRC and the appellant's accountants, it transpired that interest of £19,956 had been credited to a joint bank account in the names of the appellant and his wife in 2008/09. The appellant apologised for not including interest from this account in his 2009 tax return, pointing out that all his documents had been stolen from his apartment in Switzerland.
Following correspondence between HMRC and the appellant's accountants about the source of capital held in that account, HMRC noted from bank statements that on 4 April 2008 a capital sum of £1,140,000 was
