Rincham Ltd v HMRC

In Rincham Ltd v HMRC (TC00757 – 8 November) HMRC issued a notice under TMA 1970 s 20(8A) to a company (R) which had marketed capital redemption policies. R appealed contending that the notice was unduly onerous. The First-Tier Tribunal rejected this contention and dismissed the appeal. The tribunal noted that the company’s accounts indicated that at March 2006 it had had a capital redemption fund of more than £37 000 000 and that this had been reduced to less than £20 000 000 in the following twelve months. The tribunal concluded that it seemed probable that the company had been issuing policies for ‘sizeable sums’. On the evidence the tribunal held that ‘the notice is not onerous’.

Why it matters: The Tribunal upheld HMRC’s interpretation of the scope of TMA 1970 s 20(8A). One of the company’s directors has previously been involved in cases clarifying...