HM Revenue and Customs

The complainant requested from HM Revenue & Customs (“HMRC”) information concerning any enquiries it raised about the possible illegality of disclosures under the Liechtenstein Disclosure Facility (“LDF”). HMRC applied section 12(1) (cost of compliance would exceed the appropriate limit) to the request. The Commissioner’s decision is that HMRC has correctly applied section 12(1) to the request. He does not therefore require HMRC to take any further steps to ensure compliance with the legislation.