This was an appeal by a company against a security requirement where HMRC gave no reasons for its imposition. 

This is an appeal against a decision of HMRC requiring the appellant to provide security in the sum of £29,450 against future VAT sums due. The requirement was made by a written notification served on 27 September 2017. That notification was a bare requirement to provide security. It gave not a single reason to explain why the respondents were making the requirement. HMRC informed the appellant that if they made taxable supplies without the security being provided, the appellant would be committing a criminal offence. 

When the appellant received the notification, it contacted HMRC to ask for the reason or reasons for the requirement to provide the required security. The respondents replied by letter dated 3 November 2017, giving its reason(s) as follows: