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HMRC internal manual

Compliance Handbook

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

Where a notice is given to a subsidiary to check the tax position of the parent or one or more known subsidiaries the special rules set out at CH225510 do not apply. The usual rules about giving third party notices apply see CH23620. In summary

  • if you decide to obtain the approval of the taxpayer rather than the tribunal, you must get the approval of the parent or each subsidiary that you are checking
  • you must send a summary of reasons to the parent or each subsidiary that you are checking
  • your notice must name the parent or each subsidiary that you are checking
  • a copy of the notice must be sent to the parent or each subsidiary that you are checking.