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Developments in HMRC’s extra-territorial powers

Developments in HMRC’s extra-territorial powers

A focus on HMRC’s powers to request information and data.


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The recent decision of the Court of Appeal in R (oao Jimenez) v The First-tier Tribunal, coupled with the new Crime (Overseas Production Orders) Act 2019, represents a consolidation – if not extension – of HMRC’s powers to request information and data which is either outside the jurisdiction or in the possession or control of taxpayers who are offshore. Not only does the Jimenez FTT decision confirm that HMRC can issue Sch 36 information notices to taxpayers abroad, but HMRC can now also apply for a court order compelling access to or the provision of electronic data which is overseas. Whilst strengthening HMRC’s ability to tackle cross-border tax evasion, the developments also have significant implications for any taxpayer with a multi-jurisdictional presence.

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* First published in Tax Journal on 29 March 2019. Reproduced with permission.

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