This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our privacy notice.

Information notice was valid, but its scope was far too wide

By Mark McLaughlin, February 2024

An information notice requiring the appellant to carry out an email search using a list of specified terms was not invalid, but its scope was far too wide, and some categories represented a “fishing expedition” on the part of HMRC. 

Summary 

An information notice requiring the appellant to carry out an email search using a list of specified terms was not invalid, but its scope was far too wide, and some categories represented a “fishing expedition” on the part of HM Revenue and Customs (HMRC). 

Background 

The appellant company (PH) was the holding company of a group. In June 2014, the appellant refinanced earlier debt by issuing a £238m Eurobond to an LLP (PHLLP); PHLLP borrowed the same amount from a Luxembourg company. On 1 January 2017, the LLP transferred the Eurobond to a Barbados company. PH claimed tax relief on the interest paid on the

Subscribe to the McLaughlin’s Tax Case Library to get instant access
to the Tax Case Library.
14 day free trial , 90 day money back guarantee
Subscribe

Related or similar articles

HMRC was entitled to claw back scheme payments
By Mark McLaughlin, September 2025
Company did not meet R&D project tests and failed to prove sums claimed were spent on the project
By Mark McLaughlin, August 2024
HMRC was directed by First-tier Tribunal to issue a tax enquiry closure notice
By Mark McLaughlin, December 2022
Discovery assessment invalid as a hypothetical HMRC officer should have been aware of an insufficiency of tax
By Mark McLaughlin, June 2021
Company directors were liable for tax not paid by company
By Mark McLaughlin, September 2020