UK Finance understands the importance attached to clamping down on marketed tax avoidance, which deprives vital public services of funding and preys on naïve individuals with defective tax schemes.

As observed in the consultation, facilitation of tax avoidance by unconnected legitimate businesses is generally unwitting. UK Finance members have a broad range of legal and regulatory responsibilities, such as: to ensure safe and reliable banking and payment services; to maintain the highest standards of data protection and customer confidentiality; to tackle economic crime; to act in good faith and prevent foreseeable harm; and to maintain high standards of tax compliance. It is important that any new HMRC powers do not compromise or cut across these important obligations or add disproportionately to the risks and costs of the sector.