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HMRC internal manual

Claimant Compliance Manual

Opening and Working Enquiries: Information powers - what can be required by notice

You should only include in the information notice details which you have already requested from the customer(s) in writing. You may, over the course of your enquiry, request information on several occasions, e.g. in your opening letter, at a meeting (subsequently confirmed in writing), and in later letters. You can issue a formal information notice on each occasion, if appropriate.

The statutory powers at S19(2) do not allow you to

  • insist that the customer(s) should attend a meeting (although a meeting will often be the best way of making progress)
  • require the information or evidence to be delivered to Revenue premises. The customer(s) simply has to provide the information to you. They can decide where this should take place, and may choose their home, place of work, business premises or another appropriate location
  • have a right of access to premises. So although it will often be most convenient for all parties if any meeting takes place at the customer’s home (and you should suggest this where appropriate), you cannot insist on holding it there.