TC09548 - [2025] UKFTT 00700 (TC)

Fecha: 09-Jun-2025

Failure to provide full information?

Failure to provide full information?

65.

In relation to HMRC’s statement that the Appellant had failed to provide “the full information requested”, I said I had considered the correspondence between the parties, and I referred to that set out at §11 of this PTA Decision. I went on to cite the Appellant’s summary of the position, again already set out at §10, namely that:

(1)

In the course of the SMR compliance check, HMRC had asked 81 individual questions.

(2)

The Appellant sent HMRC over 1,000 pages of detailed and relevant evidence.

(3)

The Appellant had answered all the questions asked of it, before the appeal was made to the Tribunal.

(4)

In the context of the wider Partnership enquiries, 284 questions have been asked by HMRC and in excess of 4,000 pages of evidence has been provide by the Appellant to HMRC.

66.

I then said that although I had “not been provided with all the correspondence between the parties, it is clear from the foregoing that this not a case where HMRC have not been provided with full information”.