R(Jimenez) v FTT & HMRC – High Court holds that HMRC’s information powers do not have an extra-territorial reach

Rory Mullan successfully represented the taxpayer in R(Jimenez) v FTT & HMRC, a judicial review concerning the legality of an information notice issued to him in Dubai.

Charles J held that the FTT was wrong to conclude that an information notice could be issued extra-territorially. Although Schedule 36 FA 2008 was silent on the matter, the relevant principles of public international law meant that it should not be construed to have such an effect.