GOLD NUTS LTD AND OTHERS v THE COMMISSIONERS FOR HER MAJESTY'S REVENUE & CUSTOMS

[2016] Lloyd's Rep. FC Plus 24

FIRST-TIER TRIBUNAL (TAX CHAMBER)

Before Judge Anne Redston

Code of Practice 9 (COP9) - Contractual Disclosure Facility ("CDF") - Schedule 36 Notices - Income and corporation tax enquiries - Whether the First-tier Tribunal ("FTT") has jurisdiction to close a COP9 enquiry - The use of HMRC's powers to compel a suspect to provide information and documents for use in deciding whether or not to prosecute - Right not to self-incriminate - Right to disclosure of information - Police and Criminal Evidence Act 1984 ("PACE") - European Convention on Human Rights ("ECHR"), article 6