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International tax information exchange: are UK financial institution notices a licence to fish?
Financial institution notices (or ‘FINs’) are one of the civil information powers available to the UK tax authority (HMRC). FINs allow HMRC, by written notice, to require financial institutions to provide information that is ‘reasonably required’ by HMRC for checking the tax position of a third party, unless it would be onerous for the financial institution to provide such information. Unlike other information notices available to HMRC, there is no tribunal filter before their issue and no right of appeal to the tribunal once issued.
In the article available at the link below, David Haworth and Rose Swaffied from our London tax team highlight that FINs have become HMRC’s preferred method for obtaining information from financial institutions. This is particularly the case in relation to information requested by overseas tax authorities using international information exchange mechanisms. The article explains that just because a FIN is non-appealable, and so represents a greater power for HMRC, does not mean that tax managers’ hands are tied on receipt of a FIN.
Originally published in Tax Journal on 15 November 2024.
International tax information exchange - are UK financial institution notices a licence to fish?
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