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HMRC could not refresh time limit for penalty by reissuing information requirements

By Mark McLaughlin, November 2020

A penalty for non-compliance with an information notice was issued later than the statutory deadline, and HMRC could not refresh the time limit simply by reissuing the notice and repeating the information requirements.  

On 24 July 2017, HM Revenue and Customs (HMRC) wrote to the appellant, stating they had received information that the appellant had “purchased and disposed of a number of properties going back over a number of years” and failed to declare them. No response was received. On 11 October 2017, HMRC issued the appellant with a notice (under FA 2008, Sch 36) (Notice 1) requiring him to produce various information and documents by 20 November 2017. 

On 30 July 2018, HMRC sent a second information notice (Notice 2) to the

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