Income Tax Act 2007 section 748

Power to obtain information

Section 748 gives HMRC officers the power to require any person to provide information relevant to the transfer of assets abroad rules.

• An HMRC officer may issue a notice requiring any person to provide such particulars as the officer may reasonably require for the purposes of the transfer of assets abroad provisions, with a deadline of at least 30 days.
• The information that can be requested includes details of transactions carried out on behalf of others, transactions the officer believes warrant investigation (even if the person disagrees that any tax liability arises), and the extent of the person's involvement in specified transactions.
• A relevant lawyer — meaning a barrister, advocate, solicitor or other legal representative whose communications are protected by professional privilege or confidentiality — is not treated as having participated in a transaction merely because they gave professional advice about it.
• The power to obtain information is subject to separate restrictions on the particulars that can be required from relevant lawyers and from banks.