Lin v Revenue and Customs (INFORMATION NOTICE - failure to register for self-assessment - failure to file tax returns 0 whether information reasonably required to check tax position) [2025] UKFTT 374 (TC) (27 March 2025)

Parties

Procedural Posture

Tax Appeal (information Notice) / First Tier Tribunal Decision

Legal Issues

1. 1 Whether the Information Notice requests information outside the scope of the compliance check
2. 2 Whether the documents requested are statutory records
3. 3 Whether the information is reasonably required to check the taxpayer's tax position

Ratio Decidendi

The Tribunal has no jurisdiction to consider appeals against requests for statutory records (items 1 and 2). For items 3 and 4, the information is reasonably required to check Mr Lin's tax position given his failure to file tax returns and incomplete information provided. The Information Notice is confirmed for those items.

Court Disposition

Appeal dismissed in part, struck out in part

Orders

• Appeal against items 1 and 2 of the Information Notice struck out for lack of jurisdiction
• Appeal against items 3 and 4 dismissed and Information Notice confirmed