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HMRC internal manual

Compliance Handbook

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HM Revenue & Customs
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Dishonest tax agents: file access notice: appeal against a file access notice: document holder is not a tax agent

If a file access notice is issued to a document-holder who is not the tax agent then that person can request a review or appeal against the file access notice on the grounds that it would be unduly onerous to comply with it. See ARTG2100+ for more information on appeal and review rights

Note: The tax agent cannot appeal against a file access notice on the grounds that it is unduly onerous.

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 why complying with the file access notice would be unduly onerous.

FA12/SCH38/PARA20