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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Dishonest tax agents: file access notice: what the file access notice must contain

Our request in the file access notice must be reasonable. A file access notice can request particular relevant documents to be provided, or it can globally request all relevant documents, see CH182600, that are within that person’s possession or power.

The file access notice does not need to identify the clients of the tax agent, but where the file access notice is addressed to anyone other than the tax agent the notice must name the tax agent.

A file access notice may require the documents to be provided

  • within a specified period, see CH882620 
  • by certain means
  • in a particular form
  • to a particular person, and
  • to a particular place.

A person may comply with a file access notice by providing copies of the requested relevant documents, unless the file access notice states that it requires only original documents, see CH882630.

See CH182990 for guidance on how long we can hold the documents received under a file access notice.