Rory Mullan KC acted for the Appellant, Asset House Piccadilly Limited who were challenging an information notice issued pursuant to powers conferred by paragraph 40 Schedule 16 Finance (No 2) Act 2017 and Schedule 36 Finance Act 2008 (“Schedule 36”). The FTT concluded that while the HMRC officer may not have fully understood the detail of the meaning of “abusive tax arrangements” in the context of the GAAR that did not mean that her suspicion that the Appellant is liable to a penalty was not reasonably formed”. All that was required is that she had reason to suspect and on the evidence she did. The FTT also concluded that it was not an abuse of process to require information when it might be used in other proceedings and that there was no breach of the privilege against self incrimination.