Information requested by HM Revenue and Customs in relation to self-employment income in the appellant’s self-assessment return was ‘reasonably required’ to check his tax position. 

On 1 November 2018, HM Revenue and Customs (HMRC) issued a notice (under TMA 1970, s 9A) to open an enquiry into the appellant’s self-assessment return for the tax year 2016/17. HMRC subsequently issued an information notice (under FA 2008, Sch 36) requesting information relating to the appellant’s self-employment income. On 26 November 2019, HMRC issued a £300 initial penalty for non-compliance with the notice. The appellant appealed.

The issue for the First-tier Tribunal (FTT) was whether the information requested by HMRC was reasonably required to check the appellant’s tax position. The information was under the following broad headings: (1) ‘Takings build up’; (2) ‘Business economics model’; (3) ‘Sales