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HMRC internal manual

Appeals reviews and tribunals guidance

Applications to the tribunal: dispute over privileged communication - information notice given during inspection of premises

Action by person Action by HMRC Time limit for action
Tell the inspecting officer which documents required by the notice are in dispute    
Place the disputed documents(s) or copies of them, in an appropriate container so that the contents cannot be seen. Seal, label and sign the container and give to the inspecting officer. Inspecting officer to countersign the container  
  Inspecting officer to give container to the tribunal with the seal intact, together with an application*, see ARTG7540, to the tribunal to decide the matter 42 working days of having been given it by the person

 *There is no form for making this application, a letter to the tribunal is acceptable. The Tribunals Service address is:

Upper Tribunal (Tax and Chancery Chamber)
5th Floor
Rolls Building
Fetter Lane