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HMRC internal manual

Compliance Handbook

CH177240 - Sanctionable conduct by tax advisers: file access notice: appeal against a file access notice: document holder is a tax adviser

A file access notice issued to a tax adviser that has been pre-approved by the Tribunal may not be appealed.

If we issue a file access notice without Tribunal approval, the tax adviser may appeal the file access notice or any requirement within it.

The notice of appeal must be given

  • in writing to the officer who issued the file access notice, and
  • within 30 days of the file access notice being issued.

The notice of appeal must state the grounds of appeal.

The tribunal may confirm, vary or set aside the notice or a requirement in it following an appeal. The tribunal’s decision is final.

FA12/SCH38/PARA20