In Metropolitan International Schools Ltd v HMRC [2021] TC08322, the First Tier Tribunal (FTT) reduced the scope of a widely drafted Schedule 36 Information Notice. Items such as 'all computer records' were not reasonably required as there was no ground to believe that record-keeping was inaccurate. Items such as board minutes and marketing material had no bearing on tax return entries. Using its powers, the FTT re-made the Notice.

The FTT found that:

The FTT remade the Notice to exclude the items that were not reasonably required.

Useful guides on this topic

Schedule 36 information notices
What is a Schedule 36 Information Notice? When can HMRC issue one? What rights does the taxpayer have when an information notice is issued?

Penalties: Schedule 36 information notices
This is a freeview 'At a glance' guide to penalties and Information Notices.

External links

Metropolitan International Schools Ltd v HMRC [2021] TC08322


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