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Tax and the City review for April 2021

The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Financial institutions notices

Finance Bill 2021 published on 11 March includes the legislation to bring in the new financial institution notice (FIN) allowing HMRC to obtain information and documents from a financial institution for the purpose of checking the tax position of a taxpayer (which does not have to be an individual) or for collecting a tax debt. A FIN can be issued from the date of royal assent of FA 2021 regardless of when the tax liabilities or tax debt in question arose.

HMRC does not require the prior approval of the tax tribunal for this notice unless HMRC has reasons for not notifying the taxpayer of the details of the request and the reasons for it. The government argues that FINs are essential for the UK to be able to meet the...

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