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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Information & Inspection Powers: Conditions and safeguards: Restrictions: Tax advice: who to issue the notice to

You must send the information notice to the person and not to the tax adviser.

Communications between the tax adviser and their client, or any other tax adviser of the client, the purpose of which is to give or obtain tax advice about any of that person’s tax affairs cannot be included in an information notice issued to the tax adviser.

FA08/SCH36/PARA25 (1)