Schedule 36 information notices: burden of proof | Practical Law

Schedule 36 information notices: burden of proof | Practical Law

The First-tier Tribunal has held that, although the better view is that it is for the taxpayer to prove that information which HM Revenue & Customs has requested is reasonably required, it was arguable on the facts of the present case that the burden of proof was on HMRC.

Schedule 36 information notices: burden of proof

Practical Law UK Articles 9-614-4093 (Approx. 3 pages)

Schedule 36 information notices: burden of proof

by Norton Rose Fulbright LLP
Published on 28 May 2015United Kingdom
The First-tier Tribunal has held that, although the better view is that it is for the taxpayer to prove that information which HM Revenue & Customs has requested is reasonably required, it was arguable on the facts of the present case that the burden of proof was on HMRC.