Sharing information outside of HMRC: Disclosure in insolvency cases: Pro-active disclosures to insolvency practitioners in corporate insolvency cases
Generally in corporate insolvency cases the information you are likely to have will relate to the company itself and so can be disclosed freely to the insolvency practitioner, as outlined above, because the insolvency practitioner ‘stands in the shoes’ of the company. So, for example, if a company has transferred an asset to a third party for less than it was worth prior to the insolvency, you can provide any information you have concerning that original transfer by the company because this is company information. This would include the identity of the person to whom the asset was originally transferred by the company (but not details of any subsequent transfer by the person who received the asset from the company).
However, where the information you have relates solely to a third party such as another company, or a director, but has a bearing on HMRC’s likely recoveries from the company, then you may follow the procedures outlined for pro-active disclosures to trustees in bankruptcy, but will need to exercise extreme caution. It is recommended you seek advice in all cases, and carefully record your reasoning.