This is a brief blog that highlights another aspect of HMRC’s more aggressive attitude towards taxpayers.
They sought to trawl client data held by a firm of solicitors (in fact they targeted ten) to obtain names and addresses held under Money Laundering regulations. Since the taxpayer held this personal data as required by the Money Laundering Regulations 2007, HMRC argued that it was a ‘relevant data holder’ under FA 2011, Sch 23, therefore it should make such data available to HMRC.
The Tribunal was very restrained in finding against HMRC. But I feel sure they will try again!