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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: taxpayer notice: what can be included in a taxpayer notice

The information or documents you ask for must be in the person’s power or possession, see CH22120.

A taxpayer notice can ask for statutory records, see CH21700, and/or any other information or documents that are reasonably required by you for the purpose of checking the person’s tax position, see CH21300.

There is no right of appeal against a requirement for a statutory record. For other information or documents, the key test is whether you reasonably require the information to carry out the check. You do not have to have evidence that it will definitely affect the tax position only that it is reasonably required to carry out the check.

Statutory records are defined at CH21700.