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Tribunal Hearing For Approval Of Third-Party Notices Could Not Include Companies And Individuals

By Mark McLaughlin, March 2019

An application to the First-tier Tribunal by companies and individuals to whom HMRC proposed to send third-party information notices for a direction that they should be permitted to attend the hearing of HMRC’s application for approval of the issue of those notices was refused.  
 
HM Revenue and Customs (HMRC) opened enquiries into the corporation tax returns of three companies. HMRC subsequently considered that they needed to examine the financial position of the directors and shareholders of the companies and their spouses, to establish whether there was evidence of cash extraction from those companies.  
 
HMRC applied to the First-tier Tribunal (FTT) for approval of third-party notices addressed to the individuals, requiring them to provide information and documents for the 12-month period to 31 March 2013 in respect of personal bank accounts, credit card accounts, land/property and other

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