Identity Unknown Notices

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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