Finance Act 2014

273 Confidentiality

(1) No duty of confidentiality or other restriction on disclosure (however imposed) prevents the voluntary disclosure by a relevant client or a relevant intermediary to HMRC of information or documents about—

(a) a monitored promoter, or

(b) relevant proposals or relevant arrangements in relation to which a monitored promoter is a promoter.

(2) “Relevant client” means a person in relation to whom the monitored promoter mentioned in subsection (1)(a) or (b)—

(a) has made a firm approach in relation to a relevant proposal with a view to making the proposal available for implementation by that person or another person;

(b) has made a relevant proposal available for implementation by that person;

(c) took part in the organisation or management of relevant arrangements entered into by that person.

(3) “Relevant intermediary” means a person who is an intermediary in relation to a relevant proposal in relation to which the monitored promoter mentioned in subsection (1)(a) or (b) is a promoter.

(4) The relevant proposal or relevant arrangements mentioned in subsection (2) or (3) need not be the relevant proposals or relevant arrangements to which the disclosure relates.