Applications were not made by the taxpayer, third party or someone acting on their behalf in accordance with regulations, so the tribunal did not have the jurisdiction to determine the applications, which were therefore struck out. 

HM Revenue and Customs (HMRC) issued third-party information notices (under FA 2008, Sch 36, para 2) to solicitors (N) and a company (C). N and C claimed legal professional privilege (LPP) over certain documents. The claims for LPP were rejected by HMRC. The appellant company applied (under the Information Notice: Resolution of Disputes as to Privileged Communications Regulations 2009, SI 2009/1916, reg 5(5)) for the First-tier Tribunal (FTT) to consider and resolve the dispute. However, HMRC contended that the appellant did not have standing to make the application and called into question the FTT’s jurisdiction in relation to them. 

It was common ground that, having received information notices under FA