Information and documents specified in an information notice were reasonably required for the purposes of checking the taxpayer’s tax position, and HMRC were entitled to undertake a ‘fishing expedition’ and did not need suspicion in order to check a tax return.
HM Revenue and Customs (HMRC) opened an enquiry (under TMA 1970, s 9A) into the appellant’s tax return for the year ended 5 April 2014 on 14 December 2015. His representative’s written response dated 20 December 2015 pointed out (among other things) that HMRC’s enquiries into the appellant’s tax returns for the years ended 5 April 2012 and 2013 had been closed without amendment.
HMRC considered that it had legitimate questions about the appellant’s business interests, and requested information about the terms of loans to third parties. However, the appellant’s position was that HMRC, having received the
