Offshore information

21 September 2009

Issue: 4224 / Categories: Tax cases , Admin

Re. application by CRC for approval to serve notice on financial institution (TC148); re. application by CRC for approval to serve notice on financial institution (TC149)

The First-tier Tribunal heard two cases where HMRC applied for consent to serve notices under FA 2008 Sch 36 para 5 on financial institutions to obtain documents about customers with UK addresses with non-UK bank accounts.

The first financial institution had associated companies in the Channel Islands and resisted the issue of the notice saying that according to the figures there was no serous prejudice to the collection of tax there could be problems with confidentiality the notice should stop at 5 April 2008 rather than 31 March 2009 and it was unduly onerous.

The second institution had a subsidiary in the Isle of Man which held information on some 3 600 relevant individuals. It appealed against the notice on the grounds that the extraction of the information would take 300 man days to obtain and that the documents would be...

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