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How is HMRC using financial institution notices?

Jack Prytherch (CMS) discusses the key updates from the first report on HMRC’s use of financial institution notices.

Financial institution notices (FINs) were introduced with effect from June 2021 in the face of widespread concern about the removal of the key safeguards normally associated with HMRC information notices. In light of such controversy an annual report is now required to be laid before Parliament on HMRC’s use of FINs in order to keep this power under review. The first such report was published on 26 January 2023 and covers the period from 1 July 2021 to 31 March 2022 (see bit.ly/HMRCreportonFINs).

Introduction of FINs

Pursuant to FA 2021 (amending FA 2008 Sch 36) FINs were introduced from June 2021 as a new type of information notice aimed specifically at ‘financial institutions’ (the meaning of which is discussed below). Importantly the legislation still provides HMRC...

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