CSOH 55 (2009) Paulden Activities Limited & Others v HMRC

Paulden sought Judicial Review of HMRC S20 TMA 1970 information notices - HMRC won

Case Summary:

This case is related to a long running enquiry into tax planning arrangements. HMRC, at a private hearing before a Commissioner, had presented evidence to justify S20 TMA 1970 notices to be issued. This was challenged in judicial review. But the Court of Session held that there was a presumption of regularity in the Inspector’s and Commissioner’s behaviour and Paulden etc had not discharged the onus of showing otherwise.