ICAS response to HMRC's consultation on financial institution and tax adviser notification requirements

ICAS has responded to the HMRC's consultation on draft regulations and guidance for the financial institution and tax adviser notification requirements.

12 February 2016

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General Comments

ICAS has concerns about the informal nature of the consultation in 2015 on the original proposals, and the current consultation on the draft regulations and guidance.

Our concerns are:

  • Interested stakeholders have almost certainly been omitted from this consultation and the one in 2015
  • Due to the limited and informal consultations many of those affected will not be aware of the notification requirement
  • The deadline for responses on the draft regulations and guidance is very short so that it is unlikely that we can gather a full range of views from our members
  • Key components, the draft HMRC notification document, and the draft set wording for the covering letter, are not available.


  • Consultations and responses
  • Tax

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