Tax Collection and Management (Wales) Act 2016 section 89

Power to require information and documents about persons whose identity is not known

Section 89 deals with the power of the Welsh Revenue Authority (WRA) to issue notices requiring a person to provide information or documents where WRA does not know the identity of the taxpayer or taxpayers it is checking.

• WRA can issue an "unidentified third party notice" to require someone to hand over information or documents needed to check the tax position of a person or group of persons whose identities are unknown to WRA.
• Before the notice can be issued, the tribunal must approve it, and the application for approval can be made without notifying the recipient in advance.
• The tribunal will only approve the notice if the information is not readily available elsewhere, there are grounds to believe the unidentified person or persons may have breached devolved tax law, and any such breach is likely to have caused or to cause serious prejudice to the assessment or collection of devolved tax.
• When granting approval, the tribunal may modify the notice as it sees fit.