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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: third party notice: partnerships: notice to external third party to check one partner

If you are giving a notice to a third party who is a person other than a partner, for the purpose of checking the tax position of one partner in their capacity as a partner, the usual rules for giving third party notices apply, see CH23620. In particular

  • The notice must name the partner who is being checked.
  • The partner must be given a copy of the notice.
  • If the notice is to be approved by the tribunal, the partner needs to be given a summary of the reasons why the information and documents are required, see CH24160. 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.