HMRC’s New Powers: Tax Authority Can Now Demand Documents Beyond Scheme Promoters
HMRC has new powers to demand information in tax avoidance cases. In September 2026, it published guidance on the new anti-avoidance information notices (AAINs). They come from Part 6 of the Finance Act 2026. Until now, the focus was mostly on the promoters of schemes. But the new notices also reach the people and businesses around them. What has changed HMRC can send a notice to anyone it reasonably suspects is connected with promoting or facilitating tax avoidance. It does not need to prove that tax was lost. It also does not need to show that the scheme fails, or that the recipient committed an offence. The test is simpler. The information must be reasonably required to monitor compliance with specified anti-avoidance rules, or to consider action under them. The notices work alongside the existing powers in Schedule 36 of the Finance Act 2008. Who can receive a notice The term "connected person" is deliberately broad. It can cover directors, employees, partners, trustees and advisers. It can also cover anyone who made a scheme available, organised it, managed it or benefited from it. In addition, HMRC can approach third parties that hold information about such...