»Ê¹ÚÌåÓýapp

Before determining whether there has been a breach, HMRC’s Commissioners must first commission an Independent Reviewer to give an opinion on whether there has been a breach of the Code (subject to no GAAR notice having been given: see BKM506500), and if so whether HMRC’s Commissioners should publish the name of a bank as having breached the Code. »Ê¹ÚÌåÓýapp matter will be referred to the Independent Reviewer once the bank is notified of TDRB’s conclusion.

»Ê¹ÚÌåÓýapp legislation requires that the Independent Reviewer consider the particular bank’s conduct when determining whether they have breached the Code â€� FA14/S287. »Ê¹ÚÌåÓýapp Independent Reviewer has an obligation to follow the Protocol as far as it is relevant to their functions.