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HMRC can seek information about payments from offshore trusts (Lawson v HMRC)

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Published on: 01 December 2021

Published by a LexisNexis Private Client expert

Table of contents

What are the practical implications of this case?
What was the background?
What did the court decide?
Case details

Article summary

Private Client analysis: In Lawson v HMRC, the First-tier Tribunal (FTT) (Tax) confirmed that HMRC’s power to request information from a taxpayer in Schedule 36 to the Finance Act 2008 (FA 2008) applies to details of payments made to a UK-resident taxpayer from an offshore trust, including such information as will allow them to determine whether such payments should be treated as capital or income. The power can also extend to information about years before and after the one for which HMRC has opened the enquiry. Written by Joshua Winfield, barrister at Radcliffe Chambers.

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