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Documents requested in information notice were statutory records and were also reasonably required

By Mark McLaughlin, March 2025

An employer’s appeal against an information notice was dismissed as the documents requested were statutory records and in any event were reasonably required for checking the appellant’s tax position. 

On 8 March 2023, HM Revenue and Customs (HMRC) notified the appellant that it had been selected by HMRC to check its business records for the period 7 March 2022 to 8 March 2023 to make sure it was meeting its tax obligations as an employer. Various information and documents were provided in response (through the appellant’s accountant). HMRC subsequently requested further records. On 25 September 2023, the appellants’ solicitor wrote to HMRC stating the appellant disputed that the items requested were statutory records or reasonably required by HMRC to check the appellant’s tax position. Following a statutory review, the appellant appealed. 

The appellant’s grounds of appeal included that the requested

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