UKFTT 174 (2009) HMRC Request to issue information notices to 308 Financial Institutions

HMRC Request to issue information notices to 308 Financial Institutions - approval given

Case Summary:

This case underpins the New Disclosure Opportunity. HMRC approached the First Tier Tax Tribunal asking for approval to issue information notices to 308 Financial Institutions requiring them to provide details of offshore accounts held by people with UK addresses. This was under the new information powers in Schedule 36 FA 2008 and like all the earlier requests under the old legislation they were approved.

The information must be supplied within 90 days of the notices being issued. Thus it is unlikely that HMRC will even have the information before the expiry of the New Disclosure Opportunity registration date on 30 November 2009.

It is possible some institutions will appeal the notice on the grounds that it is unduly onerous to comply (Para 31 Schedule 36)