The Court of Appeal held that the giving of an information notice to a person abroad did not offend the sovereignty of the state in which the person was located, and HMRC’s power to issue an information notice could not properly be interpreted as being subject to any territorial limit. 
 
Summary 
 
The Court of Appeal held that the giving of an information notice to a person abroad did not offend the sovereignty of the state in which the person was located, and HMRC’s power (in FA 2008, Sch 36, para 1) to issue an information notice could not properly be interpreted as being subject to any territorial limit. 
 
Background 
 
The respondent, a UK national who resided in Dubai (and who also had a Spanish passport), was subject to an investigation by HM Revenue and Customs (HMRC) into his tax position. The principal