Adequate information provided

HMRC issued information notices under FA 2008 Sch 36 to several banks and a firm of accountants in respect of their clients after a request from the Australian Tax Office (ATO)

The ATO was investigating an avoidance scheme involving foreign jurisdictions companies including ones in the UK beneficially owned by Australian residents.

The inquiry showed the accountancy provided nominee directors and shareholders to the UK firms involved in the arrangements. The ATO was unable to obtain details from Australian resident taxpayers so wanted to obtain the information from third parties in the UK.

The claimants in the instant case were 24 companies whose documents were sought by the Revenue.

Only three firms were considered taxpayers by the department for the purposes of sch 36 para 3(3)(e) and were provided with a summary of the reasons for the notices.

The other companies were not considered to...