Under regulation 3(1) of the Income and Corporation Taxes (Electronic Communications) Regulations 2003 (S.I. 2003/282) (“the Electronic Communications Regulations 2003”) the Commissioners for Her Majesty’s Revenue and Customs (“the Commissioners”) are permitted to use electronic communications for the purposes mentioned in regulation 2(1) if the consent of the recipient has been provided and has not subsequently been withdrawn. Regulation 5(1) establishes a presumption of effective delivery in respect of information delivered by electronic communications if all the prescribed conditions relating to the use of electronic communications are satisfied.