← Back to imported archive search

Use of section 30 for FOI2022/71614

Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: The request was refused by HM Revenue and Customs .
Imported path: /opt/loancharge/imports/wdtk/requests/use_of_section_30_for_foi2022716

Open original request on WhatDoTheyKnow

Imported text

SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/use_of_section_30_for_foi2022716
TITLE: Use of section 30 for FOI2022/71614
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: The request was
refused
by
HM Revenue and Customs
.
REQUEST_SLUG: use_of_section_30_for_foi2022716
CAPTURED_AT: 2026-05-19T07:21:51+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:55:41", "first_seen_page": "2", "first_query_term": "\"Loan Charge\"", "first_date_after": "2023/01/01", "first_date_before": "2024/01/01", "matched_query_terms": "\"Loan Charge\"", "matched_date_ranges": "2023/01/01 to 2024/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2023%2F01%2F01&request_date_before=2024%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}

ATTACHMENTS:
- FOI2023_21978.pdf | https://www.whatdotheyknow.com/request/use_of_section_30_for_foi2022716/response/2281146/attach/3/FOI2023%2021978.pdf?cookie_passthrough=1 | application/pdf | 4422938 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/use_of_section_30_for_foi2022716/response/2281146/attach/html/3/FOI2023%2021978.pdf.html |  | 0 bytes

================================================================================
MESSAGE 1 [outgoing]
HEADER: Anne Charlesworth
17 February 2023
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
In HMRC's response to FOI2022/71614 several paragraphs of information were redacted. HMRC used section 31(1)(d) of the FOIA to exempt themselves from releasing it. This exemption applies to information held where the disclosure of which would, or would be
likely to, prejudice the assessment or collection of tax.
HMRC quote that there is strong public interest in public transparency but  also a strong public interest in HMRC being able to enforce the law properly. They then state it could damage the general climate of honesty.
Witholding these paragraphs reduces the transparency to the public and implies that HMRC is not certain of its use of the law in collecting taxes. This FOI is trying to ascertain that HMRC is using the law as parliament intended and collecting the right amount of tax.
Its also worth pointing out that the HMRC charter states that HMRC collects the right amount of tax, not the maximum amount of tax.
Releasing the information does not stop HMRC collecting the correct amount of taxes.
This request asks for
1) The documentation showing that a suitable officer undertook the public interest test for section 31 information in FOI2022/71614.
2) The paragraphs redacted using section 31  in FOI2022/71614 as HMRC have used this exemption incorrectly
Yours faithfully,
Anne Charlesworth

================================================================================
MESSAGE 2 [outgoing]
HEADER: Anne Charlesworth
21 March 2023
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
I have not received a response to this request. By law HMRC should have responded by 20/3/2023.
Please advise the reason for the delay.
Yours faithfully,
Anne Charlesworth

================================================================================
MESSAGE 3 [outgoing]
HEADER: Anne Charlesworth
24 March 2023
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
I still have no received an acknowledgement of this request for information despite the WhatDoTheyKnow website confirming the delivery of the initial request on 17/2/2023 and the follow up request on the 21/3/2023.
This is in breach of the FOIA.
Yours faithfully,
Anne Charlesworth

================================================================================
MESSAGE 4 [incoming]
HEADER: Team, FOI,
        HM Revenue and Customs
31 March 2023
--------------------------------------------------------------------------------
Our ref: FOI2023/21978
Dear Anne Charlesworth,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 17 February.
Please accept our sincere apologies for the oversight with your request.
We have allocated the above reference which you should quote if you need
to contact us.
We are currently finalising our response and will respond as soon as
possible.
Yours sincerely
HMRC Freedom of Information Team

================================================================================
MESSAGE 5 [incoming]
HEADER: Team, FOI,
        HM Revenue and Customs
5 April 2023
--------------------------------------------------------------------------------
1 Attachment
FOI2023 21978.pdf
4.2M
View
Download
Dear Anne Charlesworth,
We are writing in response to your request for information, received 17
February.
Yours sincerely,
HMRC Freedom of Information Team

================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================

--------------------------------------------------------------------------------
ATTACHMENT: FOI2023_21978.pdf
TEXT_FILE: FOI2023_21978.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 66
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or 
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’. 
Text Relay service prefix number – 18001 
 
OFFICIAL 
 
Freedom of Information Team 
S1715 
6 Floor 
Central Mail Unit 
Newcastle Upon Tyne 
NE98 1ZZ 
Anne Charlesworth 
By email: request-950749-
0a0755c0@whatdotheyknow.com 
Email 
foi.request@hmrc.gov.uk 
Web 
www.gov.uk 
Date: 5 April 2023 
 
Our ref: 
FOI2023/21978 
 
 
Dear Anne Charlesworth 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your request, which was received on 17 February, for the following 
information: 
 
“In HMRC's response to FOI2022/71614 several paragraphs of information were redacted. 
HMRC used section 31(1)(d) of the FOIA to exempt themselves from releasing it. This 
exemption applies to information held where the disclosure of which would, or would be 
likely to, prejudice the assessment or collection of tax. 
 
HMRC quote that there is strong public interest in public transparency but also a strong 
public interest in HMRC being able to enforce the law properly. They then state it could 
damage the general climate of honesty. 
 
Withholding these paragraphs reduces the transparency to the public and implies that 
HMRC is not certain of its use of the law in collecting taxes. This FOI is trying to ascertain 
that HMRC is using the law as parliament intended and collecting the right amount of tax. 
 
Its also worth pointing out that the HMRC charter states that HMRC collects the right amount 
of tax, not the maximum amount of tax. 
 
Releasing the information does not stop HMRC collecting the correct amount of taxes. 
 
This request asks for 
1) The documentation showing that a suitable officer undertook the public interest test for 
section 31 information in FOI2022/71614. 
2) The paragraphs redacted using section 31 in FOI2022/71614 as HMRC have used this 
exemption incorrectly” 
 
Our response 
 
We have interpreted the first part of your request as a ‘meta-request’, a request for the 
recorded information we hold about the handling of the original request and the application 
of FOIA exemptions.

--- PDF page 2 ---
2 
OFFICIAL 
This information, subject to FOIA exemptions has been provided as an annex to this letter. 
As part of your request, we have reconsidered the application of section 31(1)(d) and have 
concluded that the use of this exemption was appropriate in the circumstances. Accordingly, 
redactions have been applied consistently with that of your original request. 
 
If you are not satisfied with our reply, you may request a review within 40 working days of 
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the 
top. 
 
If you are not content with the outcome of an internal review you can complain to the 
Information Commissioner’s Office. 
 
 
Yours sincerely, 
 
HM Revenue and Customs

--- PDF page 3 ---
OFFICIAL 
EMAIL 1 – 1 ATTACHMENT 
From: Team, FOI <foi.team@hmrc.gov.uk> 
Sent: 16 February 2023 13:26 
To: 
 
Subject: Request for information - Ref: FOI2022/71614 
 
Dear 
 
We are writing in response to your request for information, received 15 November. 
Yours sincerely, 
HMRC Freedom of Information Team 
 
 
40(1
40(1

--- PDF page 12 ---
OFFICIAL 
19/03/2019 
17:31pm 
Nick 
Jones 
9 
 
 
 
… 
[and] 
… 
 
 
 
 
 
 
 
 
 
 
 
 
31(1)(d)
31(1)(d)

--- PDF page 13 ---
OFFICIAL 
 
 
 
 
 
18/03/2019 
13:39pm 
Ruth 
Stainer 
13 
[Just to flag that we have noticed some of the above lines are repeated in Ruth’s email and so consequentially we 
will redact these in this email too. I have set those out below for ease of reference.] 
 
 
 
 
 
 
 
. 
 
31(1)(d)
31(1)(d)

--- PDF page 14 ---
OFFICIAL 
And s36:

--- PDF page 16 ---
OFFICIAL 
From: Harra, Jim (HMRC) <jim.harra@hmrc.gov.uk> 
Sent: 19 January 2023 08:09 
To: Secs, Perm (HMRC) <perm.secs@hmrc.gov.uk> 
Cc: Allen, Ian (HMRC Perm Secs Office) <ian.allen@hmrc.gov.uk> 
Subject: RE: s36 application for Commissioner's decision - FOI2022_71614 
 
Thanks, 
 
 
I am content to approve this. I note that section 7 of the template form says this was submitted to 
me on 13 December 2022. Is this right or does it need to be amended to say 18 January 2023? 
 
Jim Harra 
Chief Executive, and First Permanent Secretary, HMRC. Tel: 
 | mob: 
 
 | email: jim.harra@hmrc.gov.uk 
(Chief of Staff: Ian Allen | tel: 
 mob: 
 email: ian.allen@hmrc.gov.uk) 
 
 
 
40(2)
40(2)
40(2)
40(2)
40(2)

--- PDF page 23 ---
OFFICIAL 
 
Best 
 
 
 
Date/Time 
Sender Page 
Comments 
19/03/2019 
17:31pm 
Nick 
Jones 
9 
 
 
 
 
 
 
… 
[and] 
… 
 
 
 
 
 
 
 
This goes into quite a bit 
of detail about our 
compliance systems, 
how we clash data and 
how they operate. 
 
We agreed S31 FOI Act 
2000 (prejudice to the 
assessment and 
collection of tax) could 
apply. 
 
 
40(2)
31(1)(d)
31(1)(d)

--- PDF page 24 ---
OFFICIAL 
 
 
 
18/03/2019 
13:39pm 
Ruth 
Stainer 
13 
[Just to flag that we have noticed some of the above lines are repeated in Ruth’s email and 
so consequentially we will redact these in this email too. I have set those out below for ease 
of reference.] 
 
 
 
 
 
 
 
 
 
For the same reasons 
above 
31(1)(d)
31(1)(d)

--- PDF page 32 ---
OFFICIAL 
that they 
disclosed their 
scheme 
use...followed 
are numbered 
19,21,44...up 
until - cannot 
check HMRC 
systems as not 
enough detail 
given 
to other sections? was 
this redacted due to 
GDPR rules? If so, can 
the remaining 
information still be used 
in conjunction with 
other releases to 
identify the cases and 
individual taxpayers? 
cannot use the 
information to 
realistically 
identify the details 
and therefore, 
there isn’t a risk of 
it being identified 
by someone else 
19/03/2019 
17:31 
Nick 
Jones 
9 
Red text on 
enquiry 
coverage and 
HMRC systems 
The coverage of the 
enquiry and the 
discussions around 
HMRC IT systems and 
data sets could 
prejudice the 
assessment and 
collection of tax 
 
S31 
Talking about 
legacy IT systems 
will likely have no 
impact on 
collection of tax in 
the future. The 
comments here is 
also about 
generating 
statistics and not a 
liability 
18/03/2019 
13:39 
Ruth 
Stanier 
13 
Red text on 
enquiry 
coverage and 
HMRC systems 
As above 
As above 
18/03/2019 
13:26 
Ruth 
Stanier 
15 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The views from 
ministers and 
stakeholder 
engagement could be 
redacted under S36 as 
they are part of the 
policy evaluation 
process/management 
phase. 
Could an argument be 
made that the 
evaluation/discussion 
with CX could inhibit the 
free and frank exchange 
of views - Especially the 
last 3 bullet points 
This relates to the 
pre-
implementation 
and therefore the 
material isn’t part 
of the evaluation 
process. The 
material would 
need to be tested 
for S35, and we 
would not meet 
the threshold for 
this. This is also 
similar to material 
we’ve released 
before, from the 
 request 
 
40
(2)
36(2)(b)(i) and (ii)

--- PDF page 36 ---
OFFICIAL 
 
 
 
 
 
3E/03 | 100 Parliament Street, SW1A 2BQ | 
 | 
 
 
40(2)
40(2)

--- PDF page 41 ---
OFFICIAL 
Thanks, 
 
 
 
 
40(2)

--- PDF page 50 ---
OFFICIAL 
FOI Target:14th December

--- PDF page 51 ---
OFFICIAL 
EMAIL 20 – NO ATTACHMENT 
-----Original Message----- 
From: 
@whatdotheyknow.com> 
Sent: 15 November 2022 15:03 
To: Information Rights Unit (HMRC) <informationrightsunit@hmrc.gov.uk> 
Subject: Re: Request for information - Ref: FOI2022/59332 
 
[You don't often get email from 
@whatdotheyknow.com. Learn why this 
is important at https://aka.ms/LearnAboutSenderIdentification ] 
 
Dear Team, FOI, 
 
Thank you for your reponse to FOI2022/59332. 
 
It seems strange that having raised a similar request to HMT that their information rights team can 
immediately state that there are no emails within scope of this whilst HMRC invoke section 12 of the 
FOIA. 
 
Nevertheless I will start by trying to significantly reduce the scope of my request. 
 
Please search for emails that contain the term 'Loan charge' 
and the word 'concession' (this may also include the plural 'concessions') This should be for the 
emails during the month of March 2019. 
This should only be for emails that have been sent or received by Sir Jonathan Thompson, Chief 
Executive and Permanent Secretary 
Jim Harra, Second Permanent Secretary 
Angela MacDonald, Director General Customer Services 
Justin Holliday , Chief Finance Officer 
Penny Ciniewicz, Director General Customer Compliance 
Jacqueline (Jacky) Wright, Director General Chief Digital & Information Officer 
Ruth Stanier, Director General Customer Strategy & Tax Design 
Alan Evans, General Counsel & Solicitor 
Mary Aiston, Director Counter Avoidance 
 
Yours sincerely, 
 
 
 
-----Original Message----- 
 
Dear 
, 
 
 We are writing in response to your request for information, received 26 September. 
 
 Yours sincerely, 
 
 HMRC Freedom of Information Team 
 
------------------------------------------------------------------- 
Please use this email address for all replies to this request: 
@whatdotheyknow.com 
40(1
40(1
40(1
40(1
40(1

--- PDF page 52 ---
OFFICIAL 
 
Disclaimer: This message and any reply that you make will be published on the internet. Our privacy 
and copyright policies: 
https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.whatdotheyknow.com
%2Fhelp%2Fofficers&amp;data=05%7C01%7Cinformationrightsunit%40hmrc.gov.uk%7Cec3804f05f
b341e5bacd08dac71a8db4%7Cac52f73cfd1a4a9a8e7a4a248f3139e1%7C0%7C0%7C6380412141033
50888%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwi
LCJXVCI6Mn0%3D%7C3000%7C%7C%7C&amp;sdata=fFBJzm8YwhRShkJWY113EGfGDvcVliF%2FCuQ
1%2F0NhZ4k%3D&amp;reserved=0 
 
For more detailed guidance on safely disclosing information, read the latest advice from the ICO: 
https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.whatdotheyknow.com
%2Fhelp%2Fico-guidance-for-
authorities&amp;data=05%7C01%7Cinformationrightsunit%40hmrc.gov.uk%7Cec3804f05fb341e5ba
cd08dac71a8db4%7Cac52f73cfd1a4a9a8e7a4a248f3139e1%7C0%7C0%7C638041214103350888%7
CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6
Mn0%3D%7C3000%7C%7C%7C&amp;sdata=L7xKIfK3BBXjoFoSSjKm8gH%2B1XxKeu6jJlwtKYe4BMI%
3D&amp;reserved=0 
https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.whatdotheyknow.com
%2Fhelp%2Fico-anonymisation-
code&amp;data=05%7C01%7Cinformationrightsunit%40hmrc.gov.uk%7Cec3804f05fb341e5bacd08d
ac71a8db4%7Cac52f73cfd1a4a9a8e7a4a248f3139e1%7C0%7C0%7C638041214103350888%7CUnkn
own%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%
3D%7C3000%7C%7C%7C&amp;sdata=Kk0aTlXPeWf3HeLlmcihrN%2BBJTVRxqXQjeH4cTWMCj8%3D&
amp;reserved=0 
 
Please note that in some cases publication of requests and responses will be delayed. 
 
If you find this service useful as an FOI officer, please ask your web manager to link to us from your 
organisation's FOI page.

--- PDF page 53 ---
OFFICIAL 
EMAIL 1 – ATTACHMENT 1 
DISCLOSED UNDER FOI2022/71614 
 
EMAIL 2 – ATTACHMENT 1 
DISCLOSED UNDER FOI2022/71614 
EMAIL 2 – ATTACHMENT 2 
DISCLOSED UNDER FOI2022/71614 
 
EMAIL 4 – ATTACHMENT 1 
DISCLOSED UNDER FOI2022/71614

--- PDF page 55 ---
2 
OFFICIAL 
Where requested information contains the personal information of officials or members of 
the public to a degree which is contrary to their expectation of privacy, this has been 
withheld under section 40(2) FOIA. 
 
Section 40(2) of the FOI Act, by virtue of section 40(3A) provides an absolute exemption for 
third party personal data, where disclosure would contravene any of the data protection 
principles set out in Article 5 of the General Data Protection Regulation. The first data 
protection principle requires the disclosure of third-party personal data to be lawful, fair and 
transparent. We believe that releasing the information would breach the first data protection 
principle, since it would be unlawful and unfair to release the information. 
 
The exemption in section 40(2) is absolute, meaning that there is no need to weigh up the 
public interest in releasing the information against the public interest in maintaining the 
exemption. On this basis, all identifying information relating to junior officials and members 
of the public has been withheld. 
 
Taxpayer confidentiality 
 
Requested information which constitutes ‘revenue and customs information relating to a 
person’, where disclosure would either identify the ‘person’ or would enable the identity of 
the ‘person’ to be deduced, has been withheld pursuant to section 44(1)(a) FOIA. 
 
In this context, ‘revenue and customs information relating to a person’ means information 
about, acquired as a result of, or held in connection with the exercise of a function of the 
Revenue and Customs in respect of the person. 
 
Section 44(1)(a) provides: 
 
44 Prohibition on disclosure 
 
(1) Information is exempt information if its disclosure (otherwise that under this Act) by 
the public authority holding it – 
 
a) 
is prohibited by or under any enactment, ; … 
 
The enactment in this case is the Commissioners of Revenue and Customs Act 2005 (the 
CRCA). 
 
Section 18(1) of the CRCA states that HMRC officials may not disclose information which is 
held by HMRC in connection with one of its functions. 
 
For the purposes of FOIA, section 18(1) only acts as a statutory prohibition where section 
23(1) of the CRCA is also satisfied: 
 
23 Freedom of information 
 
(1) Revenue and customs information relating to a person, the disclosure of which is 
prohibited by section 18(1), is exempt information by virtue of section 44(1)(a) of the 
Freedom of Information Act 2000 (prohibitions on disclosure) if its disclosure— 
 
(a) 
would specify the identity of the person to whom the information relates, or 
(b) 
would enable the identity of such a person to be deduced. 
 
(1A) Subsections (2) and (3) of section 18 are to be disregarded in determining for 
the purposes of subsection (1) of this section whether the disclosure of revenue and 
customs information relating to a person is prohibited by subsection (1) of that 
section. 
 
(2) Except as specified in subsection (1), information the disclosure of which is 
prohibited by section 18(1) is not exempt information for the purposes of section 
44(1)(a) of the Freedom of Information Act 2000. 
EMAIL 5 ATTACHMENT 1

--- PDF page 56 ---
3 
OFFICIAL 
 
(3) In subsection (1) ‘revenue and customs information relating to a person’ has the 
same meaning as in section 19. 
 
Assessment and collection of tax 
 
Section 31 is a qualified exemption which means it must be considered whether the balance 
of the public interest favours withholding or disclosing the information. This means that even 
though the exemption is considered to be engaged; it is necessary to consider whether the 
public interest in maintaining the exemption outweighs the public interest in disclosure. 
 
Sections 31 provides an exemption if the information, which is not exempt information by 
virtue of section 30, is exempt information if its disclosure under this Act would, or would be 
likely to, prejudice - the assessment or collection of any tax or duty or of any imposition of a 
similar nature: 
 
There is a strong public interest in ensuring that HMRC is accountable and as transparent as 
possible about the way resources are applied. Publishing the information requested would, 
on the face of it, reassure the public that our compliance activities are fair and robust, and 
applied equitably across the range of customers served by HMRC. 
 
Against that, there is a strong public interest in HMRC being able to enforce the law properly 
so that the tax burden is shared equally and fairly. Providing this information may put at risk 
our compliance activities which could undermine public confidence in the tax system. 
 
This could damage the general climate of honesty among the overwhelming majority of 
taxpayers who use the system properly and that too is not in the public interest. 
 
On balance, it is not in the public interest to disclose this information 
 
 
Prejudice to the effective conduct of public affairs 
 
Section 36 provides an exemption if in the opinion of a qualified person, disclosure would or 
would be likely to: 
 
(a) prejudice collective responsibility or the equivalent in Wales and Northern Ireland; 
(b) inhibit the free and frank provision of advice or exchange of views; or 
(c) otherwise prejudice the effective conduct of public affair 
 
In this instance, the email on page 15 is considered exempt pursuant to sections 36(2)(b)(i) 
and (ii) FOIA. 
 
The information relates to reports of briefings and discussions between ministers and senior 
stakeholders, on policy options. HMRC’s qualified person considers that the disclosure of 
such information at this time would likely result in a chilling effect on officials’ ability to 
discuss and evaluate future policies. 
 
To discuss policy options effectively, officials necessarily need to be introspective, with free 
and frank discussion of what has gone well and what hasn’t. Officials must be able to 
criticise aspects of the policy that (for example) are not meeting their aims, or do not 
constitute value for money. They need to be able to do so without trepidation that these 
discussions could be publicly released during a period when the policy is still subject to 
external criticism and debate. 
 
If officials have to consider that these discussions could be released during such a period, 
their ability to interrogate a policy with the candidness and frankness required for an 
effective evaluation process will be severely inhibited. 
 
EMAIL 5 ATTACHMENT 1

--- PDF page 57 ---
4 
OFFICIAL 
Section 36 is qualified by the public interest. This means that even though the exemption is 
considered to be engaged; it is necessary to consider whether the public interest in 
maintaining the exemption outweighs the public interest in disclosure. 
 
HMRC accepts that there is a clear public interest in government departments being as open 
and transparent as possible, so as to increase accountability and inform public debate. 
 
However, it is argued that there is a more compelling public interest in preserving the safe 
space in which officials can deliberate issues and protecting the department’s ability to 
operate effectively. 
 
It is in the public interest for officials to be able to have confidential dialogue in the execution 
of their duties and for them to exchange views freely and frankly. Advice provided and 
received must be detailed and candid if it is to be of value. For all of this to occur, officials 
must be free of any inhibitions that might interfere with their ability to offer comprehensive 
input based on free and frank discussion 
 
If such information were to be disclosed, sensitive issues might not be able to be raised in 
the future, for fear that information about such issues might be disclosed and be exposed 
prematurely to public scrutiny and comment. Disclosures of this information would likely 
undermine the quality and nature of this dialogue in the future and would not be in the public 
interest. 
 
If you are not satisfied with our reply, you may request a review within 40 working days of 
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the 
top. 
 
If you are not content with the outcome of an internal review you can complain to the 
Information Commissioner’s Office. 
 
 
Yours sincerely, 
 
HM Revenue and Customs 
 
EMAIL 5 ATTACHMENT 1

--- PDF page 58 ---
OFFICIAL 
EMAIL 6 – ATTACHMENT 1 
WITHHELD INFORMATION

--- PDF page 59 ---
Record of the qualified person’s opinion 
November 2011 Version: 1.0 
OFFICIAL 
Record of the qualified person’s opinion 
Freedom of Information Act 2000 Section 36 
When dealing with a complaint regarding section 36 of the Freedom 
of Information Act 2000, the ICO will expect to see evidence of the 
qualified person’s opinion and how it was reached. We require this 
evidence in order to decide whether the opinion was a reasonable 
one. The following form sets out the minimum information that we 
expect public authorities to provide to us about the qualified 
person’s opinion, in the event of a complaint. 
Completing this form is a convenient way for public authorities to 
give us the information we need. It is intended as a tool to assist 
public authorities, but there is no statutory requirement for them to 
use it; if instead they are able to send us other documents that 
record the same information about the qualified person’s opinion, 
we will accept those. 
While the purpose of the form is to help in providing information to 
us when we are investigating a complaint, public authorities may 
also wish to use it when they are considering applying section 36, 
as part of the internal process of obtaining and recording the 
qualified person’s opinion. 
Please see the notes at the end for help in completing this form. For 
further information on section 36 of the Freedom of Information Act 
2000, please see our guidance document on Prejudice to effective 
conduct of public affairs (section 36). 
This form only records the qualified person’s opinion under section 
36(2) of the Freedom of Information Act. If the qualified person’s 
opinion is that section 36(2) is engaged (ie that disclosure of the 
information would or would be likely to cause prejudice or 
inhibition), the public authority must then carry out the public 
interest test. As a matter of good practice, public authorities should 
also keep a record of the factors considered in the public interest 
test and the outcome of that test. 
EMAIL 6 ATTACHMENT 2

--- PDF page 61 ---
Record of the qualified person’s opinion 
 
November 2011 Version: 1.0 
 
OFFICIAL 
I believe that this exemption applies 
to the entirety of the email. 
 
Disclosure of this material would 
affect officials’ ability to meet with 
ministers for the purposes of free 
and frank discussion. 
 
The process of meeting ministers is 
integral to officials’ ability to 
function effectively. Officials must 
be able to report on policy, discuss 
potential changes, and respond to 
ministers’ questions openly and 
frankly. Officials must also be able 
to freely relate the relevant content 
of these meetings to other officials, 
so that the department can work in 
harmony with ministers’ views. 
 
It is essential that senior officials 
are kept up to date with ministers’ 
opinions on policy issues, 
particularly where the policy in 
question is controversial and/or 
subject to significant external 
scrutiny. It is very important that 
ministers feel they can discuss live 
policy freely and frankly, to fully 
explore options for change and 
refinement. 
Similarly, it is essential that officials 
can report the substance of these 
discussions with colleagues, so that 
senior officials can be kept abreast 
of ministers’ views. 
 
Given the continued external 
interest in this policy area, the 
disclosure of these lines at this time 
would be likely to inhibit similar full 
and frank exchange of views in 
future if ministers and officials 
thought that their decisions and 
views would be published. This 
would have a negative effect on the 
minister-official meeting process. 
EMAIL 6 ATTACHMENT 2

--- PDF page 64 ---
Record of the qualified person’s opinion 
 
November 2011 Version: 1.0 
 
OFFICIAL 
Notes for completing this form 
 
2. Where the public authority itself, rather than an individual, has 
been authorised as the qualified person, the name will be that of 
the highest decision making body of the authority. 
 
4. Please refer to section 36(5) of the Freedom of Information Act 
2000 for the list of qualified persons. 
 
8. This lists the subsections of section 36 which the qualified person 
was asked to consider. 
 
The full text of section 36(2) is as follows: 
 
(2) Information to which this section applies is exempt 
information if, in the reasonable opinion of a qualified person, 
disclosure of the information under this Act— 
(a) would, or would be likely to, prejudice— 
(i) the maintenance of the convention of the 
collective responsibility of Ministers of the Crown, 
or 
(ii) the work of the Executive Committee of the 
Northern Ireland Assembly, or 
(iii) the work of the Cabinet of the Welsh 
Assembly Government. 
(b) would, or would be likely to, inhibit— 
(i) the free and frank provision of advice, or 
(ii) the free and frank exchange of views for the 
purposes of deliberation, or 
(c) would otherwise prejudice, or would be likely 
otherwise to prejudice, the effective conduct of public 
affairs. 
 
12. This lists the subsections of section 36 which the qualified 
person decided were engaged. Please tick the relevant 
subsection(s), and in each case indicate whether the prejudice or 
inhibition would or would be likely to occur and the reasons for this. 
 
13. This is the date on which the qualified person’s opinion was 
given. If the form is completed after that, the date entered here 
must still be the date on which the opinion was given. 
 
14. Where the public authority itself, rather than an individual, has 
been authorised as the qualified person, the form should be signed 
on behalf of the highest decision making body of the authority. In 
that case, please also print the name of the person signing on 
behalf of that body. 
EMAIL 6 ATTACHMENT 2

--- PDF page 65 ---
OFFICIAL 
EMAIL 7 – ATTACHMENT 1 
DUPLICATE OF EMAIL 6 – ATTACHMENT 2 
EMAIL 9 – ATTACHMENT 1 
DUPLICATE OF EMAIL 6 – ATTACHMENT 2 
EMAIL 9 – ATTACHMENT 2 
WITHHELD INFORMATION 
EMAIL 11 – ATTACHMENT 1 
DISCLOSED UNDER FOI2022/71614 IN REDACTED FORMAT