If it is known that arrangements have been made to hide or launder monies from evasion through financial institutions, nominees or others, HMRC can issue an identity unknown notice. This is a written notice requiring a person to provide information or documents reasonably required to check the tax position of either:-


    • A person whose identity the officer does not know or


    • A class of person whose individual identities are not known.




An identity unknown notice can be used by HMRC, for example, to require banks to provide information about off-shore bank accounts.


Before a notice can be issued an Authorised Officer must get the approval of the Tribunal except where the notice is given to:-


    • A partner to check the tax position of a partner whose identities are not known


    • A parent company for checking the tax position of an unknown subsidiary.


The Tribunal must be satisfied that there are reasonable grounds for believing that there has been a failure to comply with tax law that may seriously prejudice the assessment or collection of tax and that the information cannot be obtained in any other way.


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