The appellant, Surat Singh Sangha, was a director and sole shareholder of a company based in Hong Kong, known as Evolution Drinks Hong Kong Limited, which was wound up in 2017. He also held shares in a US company called Octavian Securities where he attended meetings and built up contacts for the business, and was a director at Asiana Ltd.

Sangha went to the First Tier Tribunal (FTT) disputing whether information and documents required by HMRC to check his tax position were ‘reasonably required’.

HMRC had issued an information notice under Schedule 36 to Finance Act 2008 (FA 2008) on 13 October 2021, and then a varied notice on 4 February 2022 following a review. This related to a demand for tax on estimated income of £196,250 over a two-year period.