In R (oao Jimenez) v HMRC [2019] EWCA Civ 51, the Court of Appeal held that HMRC can issue a taxpayer notice to a UK national resident in Dubai. In doing so, it has added to the revenue’s armoury in the battle against tax evasion, aligning the global reach of its information-gathering powers with those of the Serious Fraud Office. Whilst enforcement abroad will be difficult, there is a sting in the tail, at least as far as assets held in the UK are concerned.

Speed read : In The Queen on the application of PML Accounting Limited v The Commissioners for HM Revenue and Customs [2018] EWCA Civ 2231, the Court of Appeal held that the taxpayer was not able to argue the invalidity of a taxpayer notice as part of its penalties...