Information requested in an information notice about distributions received by an individual from an offshore discretionary trust was reasonably required to check the individual’s tax position.

In January 2019, the appellant submitted his self-assessment return for the tax year ended 5 April 2018. In March 2019, HM Revenue and Customs (HMRC) opened an enquiry into that tax return, enclosing a schedule setting out the documents and information required. Following correspondence, HMRC wrote to the appellant informally requesting information.