CHALLENGE INFORMATION NOTICES
HMRC Information Notices: Strategic Defence & Privacy Protection
A HMRC Information Notice is more than a request; it is a powerful enforcement tool. Whether it is a Taxpayer Notice, a Third party Notice, or a Financial Institution Notice (FIN), these demands often feel like a "fishing expedition."
As a tax litigation solicitor specialising in tax disputes, I provide the technical precision required to challenge these notices, ensuring you only provide what is strictly "reasonably required" by law.
UNDERSTANDING THE DIFFERENT TYPES OF NOTICES
Not all notices are created equal, and your rights to challenge them depend on how they were issued:
Taxpayer Notices: If issued without prior Tribunal (FTT) approval, you have 30 days to appeal. I challenge these on the grounds of "reasonable requirement" or if they demand documents that aren't part of your statutory records.
Third party Notices: These usually require FTT approval. I ensure your representations are heard before the notice is authorised.
Financial Institution Notices: These are harder to block but must not be "unduly onerous."
STATUTORY SAFEGUARDS: WHERE HMRC MUST STOP
HMRC’s powers are not absolute. I help you invoke critical protections, including:
LEGAL PROFESSIONAL PRIVILEGE (LPP)
Confidential legal advice is off limits to HMRC.
THE 6 YEAR RULE
HMRC generally cannot demand documents older than six years.
POSSESSION OR POWER
You cannot be penalised for not providing what you do not have.
WHY WORK WITH AN INDEPENDENT SPECIALIST?
Large firms often delegate cases to junior staff. When you instruct me, you receive direct, senior level expertise. I personally vet every request to prevent "scope creep" and protect you from the £300 initial penalties and £60 daily fines for non compliance.
