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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Information notices: Identification notice: Examples

This page provides several examples where you may consider using an identification notice to identify a person.

Example 1 - purchases overseas with UK credit card

An overseas tax authority reports that a single UK-issued credit card has been used to buy 27 bathroom suites at a building supplies store in their country. They are included in purchases totalling £79,000 in a twelve month period. The overseas tax authority does not have the name of the buyer but they have provided HMRC with the credit card number used.

The risk is that the credit card holder is a trader and, at that level of purchases, should probably be VAT registered.

Subject to the usual requirements of any exchange of information request from overseas, the authorised officer can give an identification notice to the credit card company requiring identity information.

Example 2 - purchases made in the UK with UK credit card

The Customer Compliance Manager (CCM) for a building supplies store located in the UK provides a set of information to RIS. The information consists of a list of the credit card details for all cards that have been used over the last 12 months to buy £35,000 or more of goods. This list would constitute a ‘class of persons’. The authorised officer would still be able to issue an identification notice to each of the credit card companies who have issued cards on the list.

Example 3 - funds withdrawn overseas

An overseas tax authority reports that a UK credit card had been used to take out €90,000 in cash from cash machines in their country. They have the credit card number but want to know the identity of the card holder. The authorised officer could give an identification notice to the issuer so long as the cash is reasonably believed, on the evidence provided, to relate to a tax covered by FA08/SCH36. No such notice could be given if the overseas authority believed that the funds might relate to the proceeds of crime generally, such as a bank robbery, rather than to a tax position.