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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
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Dishonest tax agents: file access notice: appeal against a file access notice: overview

A file access notice must be approved by the tribunal before it can be issued to a person. A file access notice can be issued to a person who is not the tax agent.

The tribunal’s decision is final unless the appeal is made by a document-holder who is appealing on grounds that it would be unduly onerous to comply, see CH183040.

If a file access notice is issued to a document-holder who is not the tax agent, then that person can appeal against the file access notice on the grounds that it would be unduly onerous to comply with it. The tax agent cannot appeal against a file access notice.

The tribunal may confirm, vary or set aside the notice or a requirement in it following an appeal by the document-holder on grounds that the notice is unduly onerous. The tribunal’s decision is final.

FA12/SCH38/PARA20