Taxes Consolidation Act 1997 section 808

Power to obtain information

Section 808 empowers Revenue to require any person to furnish information needed to enforce the transfer of assets abroad provisions, subject to protections for solicitor-client confidentiality and ordinary banking transactions.

  • Revenue may issue a written notice requiring any person to provide, within at least 28 days, whatever particulars they consider necessary for the purposes of the transfer of assets abroad rules in sections 806, 807, 807A, 807B, 807C and 809.
  • The information that may be demanded includes details of transactions carried out on behalf of others, transactions Revenue consider worth investigating regardless of the recipient's own view on liability, and whether the person has participated in specified transactions.
  • Solicitors are protected from being treated as participants in a transaction merely because they gave professional advice, and cannot be compelled (without client consent) to provide more than names and addresses of the parties involved.
  • Banks are not obliged to disclose details of ordinary banking transactions with customers, unless the bank has been involved in the formation or management of an offshore close company or in the creation or execution of a non-resident settlement.

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