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25 August 2009 / Simon Airey
Issue: 4220 / Categories: Comment & Analysis , LDF , NDO , ODF
SIMON AIREY gives an overview of the FA 2008, Sch 36 notices against financial institutions

KEY POINTS

  • New approach from HMRC in obtaining disclosure notices.
  • Schedule 36 in action.
  • Nature of accounts affected.
  • Only 90 days to comply with the notice.
  • Will HMRC take a pragmatic approach?

Over the past three years several banks have been served with compulsory disclosure notices by HMRC forcing them to surrender information relating to taxpayers who may have tax liabilities in respect of undeclared assets and income overseas.

Various classes of taxpayer were targeted principally being those who have or have had some form of address in the UK and an overseas bank account or credit or debit cards linked to such an account.

Over 400 000 names have been provided to HMRC as a result of the notices obtained to date and in excess of £400 million...

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