In appeals against discovery assessments and information notices, the appeal against the discovery assessments could be stayed behind the appeal against the information notices. 

In 2017, HM Revenue and Customs (HMRC) informally requested information from the appellant relating to his domicile and worldwide income, but the appellant did not provide that information. On 18 February 2020, HMRC issued information notices (under FA 2008, Sch 36) for seven of the eight years 2011/12 to 2018/19 (the exception being 2014/15). The appellant appealed against the notices on the grounds that the information was not ‘reasonably required’ because he was not domiciled in the UK (the ‘notices appeal’) and that his domicile should be decided as part of the notices appeal. 

Of the seven years for which information notices were issued, the last four were under enquiry and the status of the tax year 2014/15 was disputed (HMRC’s