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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: third party notice: where approval is required: reasons not to be given

There may be occasions when the tribunal will direct that the person need not be given a summary of reasons. For example in a case of suspected deliberate inaccuracy. At some stages of the check it will be important for us not to reveal to the person how much we already know, in order to encourage a complete disclosure.

This provision is sensitive and it is important that it is not abused. Reasons should be given unless there is a compelling case for not doing so.

It may sometimes be possible to draft a summary of some of the reasons and seek exemption only for the material that you believe must be kept secret. The tribunal might find this approach more justifiable than a total exemption.