Qualapharm Ltd v Revenue and Customs (INCOME TAX/CORPORATION TAX : Other)

INFORMATION NOTICES � whether certain documents and information required were statutory records- yes � whether notices issued other than to check the taxpayer�s tax position � no � whether the appellant�s offer of conditional compliance was compliance � no � whether reasonable excuse for non-compliance � no � appeal against notices and penalties dismissed

Sitting in public at the Royal Courts of Justice, Strand, London on 11 and 17 December 2015

H Jones, Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

The appellant had not been entirely clear in its earlier notice of appeal as to it was that it was appealing. I referred to this in an earlier appeal by this appellant (the written decision in respect of which is recorded at [2015] UKFTT 579 (TC) ): the uncertainty was resolved by the appellant filing a new notice of appeal (TC/2015/5565) against certain information notices and penalties.

The earlier hearing and decision concerned an application by the appellant for disclosure in and a stay of its application for a closure notice of enquiries into APE 31 December 2011 (�the 2011 enquiry�) and into APE 31 December 2012 (�the 2012 enquiry�). I refused the disclosure and stay applications in the course of that hearing and would have proceeded to consider the closure applications except that at that point in the proceedings the appellant withdrew the closure applications.� I therefore dismissed the proceedings.�