HMRC’s information gathering powers include issuing taxpayer notices, third-party notices and financial institution notices. The issue of a third-party notice, unlike a taxpayer notice, must be approved in advance by the FTT, while financial institution notices do not require FTT or taxpayer approval. There are penalties for failure to comply, unless there is a reasonable excuse. Restrictions on HMRC’s powers ensure that information or documents are not required if they are not in the recipient’s possession, more than six years old or protected by legal professional privilege. With continuing pressure on HMRC to increase the tax yield and in view of recent consultations on the tax administrative framework, it seems likely that HMRC’s powers will be increased further in the future.
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HMRC’s information gathering powers include issuing taxpayer notices, third-party notices and financial institution notices. The issue of a third-party notice, unlike a taxpayer notice, must be approved in advance by the FTT, while financial institution notices do not require FTT or taxpayer approval. There are penalties for failure to comply, unless there is a reasonable excuse. Restrictions on HMRC’s powers ensure that information or documents are not required if they are not in the recipient’s possession, more than six years old or protected by legal professional privilege. With continuing pressure on HMRC to increase the tax yield and in view of recent consultations on the tax administrative framework, it seems likely that HMRC’s powers will be increased further in the future.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
