Dear HM Revenue and Customs,

Could you please describe what measures you have taken to notify tax payers who may be potentially impacted by the 2019 Loan Charge as passed by the UK Parliament in the 2017 Finance Act.

In particular I need to know
1) The date of the communication
2) The medium (Spotlight, e-mail, postal mail, journal article etc)
3) Where applicable, the name of the site or journal/paper
4) Where applicable, the number of tax payers contacted (e-mail, post only)

If the information is available, please also speciify your plans for future notifications in the run up to the reporting deadline

Yours faithfully,

Nathan Hamilton

Dear HM Revenue and Customs,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of HM Revenue and Customs's handling of my FOI request '2019 Loan Charge - Taxpayer notification'.

I am very dissatisfied with the response and request an internal review.
1) Whilst I accept that the three queries broadly relate to HMRC's conduct of tax inquiries, there is sufficient difference in the nature of the questions that, to bulk them up is unreasonable and appears to have been done with the intention of avoiding providing an answer. this is supported by the stock response paragraphs provided in the "Outside FOIA" section.

2) The link Tax Avoidance Litigation Decisions covers two years only and is not current. In addition, this as well as the Press Releases say nothing about failed cases or cases which are still ongoing.

Given the size of HMRC's litigation team. you surely have some sort of case management system from which statistics can be extracted, if only for monitoring effectiveness and performance trends.

Given the 2019 Loan Charge is retrospective 20 years I am looking for evidence of HMRC prosecuting these schemes over a longer period.

3) With relation to communications regarding the 2019 Loan Charge, I am confident that you will have records of e-mail or postal mail shots that can be used to provide a partial response to my inquiry. If HMRC have made any attempts to publicize the 2019 Loan Charge in print media someone reasonably senior will have had to sign off the expenditure. With regard to mailshots, I know some people have received mail shots in June 2018 but want to determine whether HMRC has made a substantial effort to spread the word, and when this effort commenced.

Also, your answer seems to be conflating the 2019 Loan Charge and the CLSO2. I asked specifically about the 2019 Loan Charge and would be grateful if your answer focused on it.

4) A separate FOIA request will be made to establish the factual number of CLSO2 expressions of interest received.

Could I please ask you to review the above in conjunction with the original FOIA request and consider whether you could provide more information. This is a matter of quite considerable importance to a very large number of people and it is in the public interest for the facts to come out as opposed to conjecture.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/2...

Yours faithfully,

Nathan Hamilton