FA 2011 Sch 23 arguably provides HMRC its greatest weapon in its armoury of information and investigation powers. The data gathering powers cover almost every type of data holder imaginable, including employers, banks, insurance companies and other financial institutions, brokers, auctioneers, estate agents and charities under 16 broad categories. Effective from April 2012 and believed by HMRC to have extra territorial scope, companies likely to be subject to such powers should be aware of these powers, and their rights and responsibilities, bearing in mind the Data Protection Act 1998. Rights of appeal are limited. Penalties for failures can accrue on a daily basis.
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