Akash Nawbatt QC and Sebastian Purnell successfully defend derivative work product delivery up claim:  R(PML) v HMRC

In a judgment handed down on 7 April 2017 the High Court (Sir Ross Cranston) rejected the claimant’s claim for judicial review requiring HMRC to destroy work product derived from information provided pursuant to an allegedly invalid Schedule 36 Finance Act 2008 Information Notice.

The judgment provides guidance on the narrow scope of the jurisdiction of the FTT in an appeal against Schedule 36 penalties for failure to comply with an Information Notice and the circumstances in which the High Court will order delivery up of work product derived from documentation which is alleged to have been unlawfully obtained.

Akash Nawbatt QC and Sebastian Purnell appeared on behalf of the Respondent, instructed by the General Counsel and Solicitor to HMRC.

To read the full judgment, please click here.

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