The High Court held that the information powers legislation did not provide HMRC with a power to give an information notice to a taxpayer in Dubai, and so HMRC should not have given it, the First-tier Tribunal should not have approved it, and it should be quashed.
Summary
The High Court held that the information powers legislation (FA 2008, Sch 36) did not provide HM Revenue and Customs (HMRC) with a power to give an information notice to a taxpayer in Dubai, and so HMRC should not have given it, the First-tier Tribunal should not have approved it, and it should be quashed.
Background
The claimant brought proceedings for judicial review, which raised an issue of statutory construction on the jurisdiction of HMRC to give an information notice (under FA 2008, Sch 36) to the claimant in Dubai.
The claimant asserted: ‘The power to issue
