GOLD NUTS LTD AND OTHERS v THE COMMISSIONERS FOR HER MAJESTY'S REVENUE & CUSTOMS
 Lloyd's Rep. FC 249
FIRST-TIER TRIBUNAL((TAX CHAMBER))
Before Judge 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.