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HMRC internal manual

Compliance Handbook

Dishonest tax agents: file access notice: when to issue a file access notice

The file access notice must

  • only be issued in Case A or Case B situations, see CH182540,
  • be approved by the tribunal, and
  • be issued to the tax agent or any other person we believe may hold relevant documents, see CH182600.

Guidance on what the file access notice must contain is in CH182640.