Draft clauses for Finance Bill 2021 include amendments to HMRC's civil information powers. HMRC are to be given a new power to issue a 'Financial Institution Notice' (FIN) to require financial institutions to provide information to HMRC when requested about a specific taxpayer, without the need for approval from the independent tribunal that considers tax matters. This change will have effect on and after the date of Royal Assent.
The only constraints on the use of FINs will be that the officer giving the notice must have a 'reasonable opinion' that it would not be onerous for the institution to provide the information, and that it is 'reasonably required' in order to check on the taxpayer's tax position or to collect a tax debt from them.
Justine Howard
Associate Director, Tax
KPMG Crown Dependencies