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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: third party notice: groups: notice to external third party to check parent and any one or more known subsidiaries

Where a notice is given to an external third party to check the tax position of both the parent and any one or more known subsidiaries, see CH23760, the following rules apply

  • If you decide to obtain the approval of the taxpayer rather than the tribunal, you only need to obtain the parent undertaking’s approval.
  • The notice only needs to state that it is for checking the tax position of the parent and one or more of its subsidiaries. It need then name only the parent undertaking. It does not need to name the subsidiaries. This enables you to avoid having to make unnecessary (and possibly incomplete) lists of subsidiaries. But where listing the subsidiaries is likely to help the recipient to comply with the notice, you should do so. You should also name the affected subsidiaries in your description of documents and information where this helps to identify what you are seeking.
  • If the notice is to be approved by the tribunal, only the parent needs to be given a summary of the reasons why the information and documents are required. It may be appropriate to seek tribunal approval where you need to protect your information from premature exposure at an appeal hearing on the notice.
  • Only the parent needs to be given a copy of the notice.