Alvi v Revenue and Customs (INCOME TAX/CORPORATION TAX : Other) [2016] UKFTT 201 (TC) (27 January 2016)

Alvi v Revenue and Customs (INCOME TAX/CORPORATION TAX : Other) [2016] UKFTT 201 (TC) (27 January 2016)

All HMRC information requests were reasonable, clear, and necessary; the appellant must obtain documents from the trust and promoter, and no privacy rights were breached.

Source-derived case information.

Citation
[2016] UKFTT 201 (TC)
Parties
Appellant: Dr Samir Alvi; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
27 January 2016
Procedural Posture
Income Tax Appeal / First Tier Tribunal Decision
Outcome
Appeal dismissed
Legal Topics
Schedule 36 Finance Act 2008, Information Requests, Tax Avoidance Scheme, Business Expense Deduction
Tax Law Schedule 36 Finance Act 2008 Information Requests Tax Avoidance Scheme Business Expense Deduction

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 2 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

Dr Samir Alvi

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / First Tier Tribunal Decision

Legal Issues

  1. 1 Whether HMRC's information requests under Schedule 36 Finance Act 2008 were reasonable, clear, and necessary
  2. 2 Whether the appellant possessed or had power to obtain relevant documents and information
  3. 3 Whether the appellant's rights to privacy were breached by the requests

Ratio Decidendi

All HMRC information requests were reasonable, clear, and necessary; the appellant must obtain documents from the trust and promoter, and no privacy rights were breached.

Court Disposition

Appeal dismissed

Orders

  • Appellant must obtain and supply requested documents and information from trust and scheme promoter to HMRC