Summary
A company’s appeal against penalties for non-compliance with an HMRC information notice (under FA 2008, Sch 36, para 1) succeeded because the information notice was invalid.
Background
The appellant company (PML) provided accounting, tax and corporate services to contractors and consultants. An officer from HM Revenue and Customs (HMRC) wrote to PML in August 2012, stating that he was considering whether the arrangements existing between PML and its clients brought PML within the scope of the managed service company (MSC) legislation (in ITEPA 2003, Pt 2, Ch 9).
HMRC requested an initial meeting with PML, and a review of its business records. Following subsequent correspondence between HMRC and PML and its agents, HMRC issued an information notice in November 2012, under FA 2008, Sch 36, para 1. PML eventually submitted 16 boxes of documents to
