Information Powers - production of information and documents
The person can discharge their obligation if, within the time set out in the Formal Information Notice, they make available to HMRC the information or documents required by the Formal Information Notice. HMRC cannot insist on the information or documents being delivered to its office, or otherwise specify where the information should be produced.
A person can offer to;
- produce the information or documents at their own or their agent’s premises, and actually produce them by the date set out in the Formal Information Notice
- deliver the documents within the time limit to another HMRC office.
But it would not be acceptable for the person to:
- fax the HMRC office on the day on which the time limit on the Formal Information Notice expired to say that the documents were available for collection or inspection
- offer to produce documents so close to the expiry of the time limit, or in an unreasonable location.
See Johnson v Blackpool Commissioners and CIR.