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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
Updated
, see all updates

How to do a compliance check: information powers: third party notice: groups: summary table

  CH225520 CH225530 CH225540 CH225550 CH225560 CH225570 CH225580 CH225590
Notice to external third party external third party parent parent parent parent subsidiary subsidiary
To check tax position of parent and one or more known subsidiaries one or more known subsidiaries only parent and one known subsidiary parent and more than one known subsidiary one known subsidiary more than one known subsidiary parent OR one or more known subsidiaries parent AND one or more known subsidiaries
Type of notice 3rd party 3rd party combined taxpayer & 3rd party combined taxpayer & 3rd party 3rd party 3rd party 3rd party 3rd party
Para 21/21A conditions - see CH23520 no effect no effect apply to parent but not subsidiary applies to parent and all subsidiaries unless each subsidiary is named, in which case it only applies to parent and the named subsidiaries no effect applies to all subsidiaries unless each subsidiary is named, in which case it only applies to the named subsidiaries no effect no effect
Taxpayer approval required parent only each subsidiary subsidiary none subsidiary none parent OR each subsidiary parent
Appeal grounds, if not tribunal-approved too onerous only too onerous only any any too onerous only any too onerous only too onerous only
No appeal against statutory records of parent and each of its subsidiaries statutory records of each subsidiary statutory records of parent or the subsidiary statutory records of parent or any of its subsidiaries statutory records of subsidiary statutory records of parent or any of its subsidiaries statutory records of parent OR each subsidiary statutory records of parent and each of its subsidiaries
Tribunal approval required if no taxpayer approval if no taxpayer approval if no taxpayer approval optional if no taxpayer approval optional if no taxpayer approval if no taxpayer approval
Opportunity to make representations recipient recipient recipient recipient recipient recipient recipient recipient
Summary of reasons to parent only each subsidiary subsidiary none subsidiary none parent OR each subsidiary parent
If tribunal-approved, no appeal against notice or any requirement in notice notice or any requirement in notice notice or any requirement in notice notice or any requirement in notice notice or any requirement in notice notice or any requirement in notice notice or any requirement in notice notice or any requirement in notice
Name in notice  ’[Parent name] and any of its subsidiaries’ each subsidiary subsidiary  ’more than one subsidiary’ OR name of each subsidiary subsidiary  ’more than one subsidiary’ OR name of each subsidiary parent OR each subsidiary  ’[Parent name] and any of its subsidiaries’
Copy of notice to parent only each subsidiary subsidiary none subsidiary none parent OR each subsidiary parent only