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HMRC internal manual

Compliance Handbook

Dishonest tax agents: file access notice: power to access tax agent's files from third parties

We may issue a file access notice to a tax agent, or another person who we believe holds relevant documents (the ‘document-holder’), requiring them to provide the documents.

The document-holder does not have to be a tax agent or an individual. The document-holder can include a company or a partnership.

We can only issue a file access notice to a person who is not the tax agent (a third party document-holder) in either a Case A situation or a Case B situation, see CH182540, and the notice still requires approval by the tribunal.

Where we have issued a file access notice to a third party document-holder, that person can appeal against the file access notice on the grounds that it is overly onerous, see CH183000+.