Several items listed in an information notice were information and documents in relation to which neither: (a) HMRC had reasonable grounds for suspecting that tax had not been assessed (or was insufficient); nor (b) were reasonably required for the purposes of checking the appellant’s tax position.

Since 2007, when the appellant moved to the UK, he was resident in the UK for tax purposes but domiciled outside the UK. He had elected to be taxed on the remittance basis. For the tax years 2006/07 to 2012/13, the appellant declared UK bank interest as his only source of income. For 2013/14 to 2015/16, the appellant returned no taxable income on his