An information notice issued to the taxpayer as an employee was reasonably required to check her tax position, and HMRC was not required to issue a third-party notice to the taxpayer’s employer to obtain information about her employment. 

On 11 April 2023, HM Revenue and Customs (HMRC) issued an information notice relating to the appellant’s employment by her employer (OCL), particularly to check whether the employment involved tax avoidance. The information and documents required related to the period 6 April 2021 (the beginning of the tax year the appellant’s employment with OCL commenced) to 16 February 2023 (when the information request was made).  

The appellant appealed: (1) The notice required information and documents for the then-current tax year (2022/23) and no enquiry had been opened for 2021/22 so it could not be for the purposes of checking a tax position; (2) The request was onerous and more properly