Information requested by HMRC in information notices was not considered to be ‘reasonably’ required on the particular facts of the case, as the First-tier Tribunal did not consider any useful purpose would be achieved by prolonging matters by ordering information notices to be complied with before any tribunal proceedings.

The appellants were the sole director and a shareholder (JY) of a company and its secretary and a shareholder (PY). On 12 July 2012, PY transferred 100 ‘B’ shares in the company to JY’s father (GY), a resident of Cyprus.

The company subsequently paid the following dividends: (1) 4 January 2013 – £200,000 to;