It was within the jurisdiction of the First-tier Tribunal to approve the issue of a third-party information notice even though the intended recipients were not now UK resident. 

In April 2019, HM Revenue and Customs (HMRC) made an ex-parte application to the First-tier Tribunal (FTT) for approval for an information notice (under FA 2008, Sch 36, para 2) to be issued to two non-UK residents in respect of information relating to the tax affairs of a UK resident company. 

The Court of Appeal had previously ruled in R (on the application of Jimenez) v First-tier Tribunal and HMRC [2019] EWCA Civ 51 that the tribunal had jurisdiction to approve the issue by HMRC of an information notice (under Sch 36, para 1) to a non-UK resident taxpayer requiring him or her to provide the requested information about his or her tax affairs. However, the intended recipients of the