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