Legislation – Finance Act 2026

An officer of Revenue and Customs may by notice require a connected person to provide information that is, in the opinion of the officer, reasonably required for the purposes of—

(a)

monitoring the compliance of the connected person with an anti-avoidance enactment, or

(b)

HMRC taking, or considering whether HMRC could take, action against the connected person under an anti-avoidance enactment.

(2)

An officer of Revenue and Customs may seek the approval of the tribunal before issuing a notice under this section.

180Information notices: third parties

(1)

An officer of Revenue and Customs may by notice require a person to provide information that is, in the opinion of the officer, reasonably required for the purposes of—

(a)

monitoring the compliance of a connected person with an anti-avoidance enactment, or

(b)

HMRC taking, or considering whether HMRC could take, action against a connected person under an anti-avoidance enactment.

(2)

A notice under this section must identify the connected person to whom it relates.

(3)

Before issuing a notice under this section, an officer of Revenue and Customs must—

(a)

notify the intended recipient of—

(i)

the officer’s intention to issue the notice, and

(ii)

the information that would be required under the notice, and

(b)

allow the intended recipient reasonable opportunity to make representations to HMRC.

(4)

An officer of Revenue and Customs may not issue a notice under this section without either—

(a)

the agreement of the connected person identified in the notice, or

(b)

the approval of the tribunal.

(5)

The tribunal may not approve a notice unless it has been given a summary of any representations made under subsection (3)(b).

(6)

After issuing a notice under this section, an officer of Revenue and Customs must provide to the connected person identified in the notice—

(a)

a copy of the notice, and

(b)

a summary of the officer’s reasons for requiring the information.

(7)

Subsections (2), (3) and (6) do not apply to the extent the tribunal is satisfied that taking the steps in those subsections might prejudice the investigation of tax avoidance.

181Information notices: unidentified connected persons

(1)

An officer of Revenue and Customs may by notice require a person to provide information that is, in the opinion of the officer, reasonably required for the purposes of—

(a)

monitoring the compliance of an unidentified connected person with an anti-avoidance enactment, or

(b)

HMRC taking, or considering whether HMRC could take, action against an unidentified connected person under an anti-avoidance enactment.

(2)

In this section, “unidentified connected person” means—

(a)

a connected person whose identity is not known to the officer, or

(b)

a class of persons whose individual identities are not known to the officer but, of which, one or more members is a connected person.

(3)

A notice under this section may only require information that is not readily available from another source.

(4)

An officer of Revenue and Customs may not issue a notice under this section without the approval of the tribunal.

(5)

In subsection (1)(b), the reference to taking action against an unidentified connected person includes a reference to taking action against one or more members of a class referred to in subsection (2)(b).

182Information notices: identification

(1)

An officer of Revenue and Customs may by notice require a person to provide identifying information that is, in the opinion of the officer, reasonably required for the purpose of identifying an unidentified connected person.

(2)

An officer of Revenue and Customs may not issue a notice under subsection (1) unless the officer has reason to believe that—

(a)

the intended recipient of the notice could identify the unidentified connected person by reference to information provided by the officer, and

(b)

the recipient obtained the identifying information in the course of a business.

(3)

A notice under this section may only require information that is not readily available from another source.

(4)

In this section—

“identifying information” means one or more of an unidentified connected person’s—

(a)

name;

(b)

last known address;

(c)

in the case of an individual, date of birth;

“unidentified connected person” has the meaning given in section 181.

(5)

An officer of Revenue and Customs who is not an authorised officer may not issue a notice under this section without the approval of either—

(a)

the tribunal, or

(b)

an authorised officer of Revenue and Customs.

(6)

An authorised officer of Revenue and Customs may seek the approval of the tribunal before issuing a notice under this section.

183Information notices: financial institutions

(1)

An officer of Revenue and Customs may by notice require a financial institution to provide information that is, in the opinion of the officer, reasonably required for the purposes of—

(a)

monitoring the compliance of a connected person with an anti-avoidance enactment, or

(b)

HMRC taking, or considering whether HMRC could take, action against a connected person under an anti-avoidance enactment.

(2)

A notice under this section must identify the connected person to whom it relates.

(3)

An officer of Revenue and Customs may not issue a notice under this section without the approval of the tribunal.

(4)

After issuing a notice under this section, an officer of Revenue and Customs must provide to the connected person identified in the notice—

(a)

a copy of the notice, and

(b)

a summary of the officer’s reasons for requiring the information.

(5)

Subsection (4) does not apply to the extent the tribunal is satisfied that taking the steps in that subsection might prejudice the investigation of tax avoidance.

(6)

In this section—

“financial institution” means—

(a)

a financial institution under the CRS other than one which is such an institution only because it is an investment entity within section 8(A)(6)(b) of the CRS;

(b)

a person who issues credit cards;

“CRS” means the common reporting standard for automatic exchange of financial account information developed by the Organisation for Economic Co-operation and Development, as that standard has effect from time to time.