SI 2026/560 was made on 27 May 2026 and comes into force on 19 June 2026.
As per the explanatory note:
“These Regulations make provision for the resolution by the tribunal of disputes as to whether any information requested by His Majesty’s Revenue and Customs in an information notice, issued under sections 179 to 183 of the Finance Act 2026 (c. 11), is privileged. These Regulations set out the procedure to be followed where the information requested is in dispute and for resolution of such disputes by agreement or the tribunal.”
https://www.legislation.gov.uk/uksi/2026/560/contents/made
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In Schedule 36 Notices – HMRC Information Requests, tax barrister Keith Gordon encourages full compliance with legitimate requests from HMRC but also recommends that taxpayers should stand up to requests that do not meet the strict statutory criteria. The author reminds professional advisers of the risks of providing more information than the law requires.
