In a reserved written judgment handed down on 31 January 2019 in R (oao Tony Michael Jimenez) v (1) First Tier Tax Tribunal & (2) HMRC [2019] EWCA [2019] EWCA (Civ) 51, the Court of Appeal has confirmed that HMRC has power to serve a notice requiring the provision of information on a taxpayer who is outside the jurisdiction. In allowing HMRC’s appeal, the Court rejected the taxpayer’s submission that such conduct would constitute an exercise of enforcement jurisdiction in breach of international law and held that Parliament had intended this power to have extraterritorial effect. A full copy of the judgment is available here.
Jessica Wells acted for HMRC, with Sir James Eadie QC (Blackstone Chambers) and James Rivett (Pump Court Tax Chambers), instructed by General Counsel and Solicitor to HMRC.
