It is no secret that HMRC enjoys extensive information gathering powers (and most will agree that it should, with the right taxpayer safeguards in place).
These enable HMRC to request information and documents "reasonably required" to check a taxpayer's position from the taxpayer directly, by issuing a first-party notice, or from third parties who hold information relating to the taxpayer, under a third-party notice with the approval of the tax tribunal or the taxpayer's agreement or, if the third party is a financial institution, under a financial institution notice (introduced by the Finance Act 2021) without either of th...