HMRC's power to obtain information was set out in former ITA 2007, s. 771, and was framed in wide terms.

Under former ITA 2007, s. 771(1), an officer of Revenue and Customs could by notice require any person to provide such particulars as the officer ‘may reasonably require’, within such period as the officer might direct (which had to be at least 30 days).

The particulars which the person who received a notice had to provide if required to do so included particulars about:

(1)transactions or arrangements with respect to which the person is or was acting on behalf of others (former s. 771(3)(a));

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