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HMRC internal manual

Appeals reviews and tribunals guidance

Applications to the tribunal: Dispute over privileged communication - information notice given in correspondence

Action by Person Action by HMRC Time limit for action
Give HMRC a list of disputed documents required by the information notice, with a description of the nature and content of the document *   Within 20 working days of the date document(s) / information was required by the information notice
  Notify the person who gave the list, of any documents we require that we think are not privileged. Within 20 working days of receiving the list from the person
Apply to the tribunal, see ARTG7550, to decide the matter, including copies of disputed documents with the application.    Within 20 working days of the date HMRC notified them of the documents we think are not privileged.

*If the description itself would cause a dispute over privilege the description may be omitted.