Commentary

A6.613 Identity unknown information notices

Administration and compliance

A6.613 Identity unknown information notices

A6.613 Identity unknown information notices

HMRC has power to obtain information and documents from a third party for the purpose of checking the tax position of a person or class of persons whose identity is not known (based on provisions previously in TMA 1970, s 20(8A)), but extended beyond 'documents' (as previously), to 'information')1. The notice is subject to approval of the First-tier Tribunal who must be satisfied that2:

  1.  

    (a)     there are reasonable grounds for believing that the person to whom the notice relates may have failed, or may fail, to comply with the law (including the law of a territory outside the UK) relating to tax

  2.  

    (b)     such a failure is likely to have led, or to lead, to serious prejudice to the assessment or collection of tax; and

  3.  

    (c)     the

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