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HMRC internal manual

Compliance Handbook

Dishonest tax agents: file access notice: appeals against a file access notice: actions available to tribunal

Where a person who is a third party document-holder appeals against the file access notice, the tribunal may

  • confirm
  • vary, or
  • set aside

the notice or a requirement in it.

The tribunal’s decision is final.

FA12/SCH38/PARA20