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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: third party notice: where approval is required: opportunity letter

An opportunity letter issued under paragraph 3(3)(c) must conform to the same requirements as the eventual notice in relating to documents specified or described. It should be drafted as if it were the formal notice. The subsequent notice may be drafted more narrowly to reflect representations received, but must not be drafted more widely.

An example of an opportunity letter is at CHApp1.5 (Word 33KB).