CH23140 - Information & Inspection Powers: Information notices: Financial Institution Notice: Requirements

When you issue a FIN to a Financial Institution, you must always

• name the taxpayer to whom the notice relates
• at the same time, send a copy of the notice to the taxpayer whose tax position you are checking or tax debt you are collecting; and
• provide the taxpayer with a summary of the reasons why you require the information and documents. A summary of reasons must be meaningful and informative, although it does not have to reveal all the relevant data and you should not be secretive for the sake of being secretive CH225430

You can apply to the tribunal for them to disapply these requirements, but only if you consider that these requirements may prejudice the assessment or collection of tax (CH23660 & CH24220). In disapplying the requirement to name the taxpayer in the notice the tribunal has to be satisfied that this might seriously prejudice the assessment or collection of tax

You must have the approval of an authorised officer (CH21720) before making any application to the tribunal.