The obligations of a solicitors’ partnership under the money laundering regulations did not make it a relevant data-holder, and such records were not relevant data. 
 
In February 2017, HM Revenue and Customs (HMRC) issued the appellant partnership with a notice under its data gathering powers (FA 2011, Sch 23, para 1). The notice broadly required (among other things) details of beneficial owners of offshore companies and persons with beneficial interests in offshore partnerships, etc., where services were provided related to the formation of offshore companies, trusts, etc., or the creation of beneficial interests or the settling of funds in them between 6 April 2013 and 5 April 2016 inclusive. 
 
The appellant appealed; it did not accept that it was a relevant data-holder, or that it held relevant data. The dispute was whether the appellant’s requirement to keep records under the money