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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: third party notice: groups: notice to parent to check more than one known subsidiary

Where a notice is given to a parent undertaking for the purpose of checking the tax position of more than one known subsidiary, see CH23780.

  • The guidance at CH23520, relating to Self Assessment returns, applies to all subsidiaries unless each subsidiary is named, in which case the guidance about Self Assessment returns only applies to the named subsidiaries
  • The notice does not need any approval
  • If you do not seek tribunal approval, the parent can appeal the notice on any grounds, except that they have no right of appeal against a requirement to produce statutory records of any member of the group. If you decide to seek tribunal approval the parent has, in common with other tribunal-approved notices, no right of appeal
  • You do not need to give the subsidiaries a summary of reasons, although you may if you consider it appropriate. You should consider carefully and respond positively to any request by the subsidiary for a summary of reasons, provided that doing so will not jeopardise your enquiry
  • The notice does not need to name all the subsidiaries, but if you don’t name them you must say in the notice that it is for the purpose of checking the tax position of more than one of its subsidiaries.
  • There is no need to give the subsidiaries a copy of the notice.