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.

A Tax Information and Impact Note covering this instrument was published on 26th November 2025 alongside the Budget and is available on the website at https://www.gov.uk/government/collections/tax-information-and-impact-notes-tiins. It remains an accurate summary of the impacts that apply to this instrument.