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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
Updated
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How to do a compliance check: information powers: third party notice: partnerships: notice to a partner, whose tax position is not being checked, to check one partner

When you give a notice to a partner, whose tax position is not being checked, to check the tax position of one other partner in their capacity as a partner, then

  • if the recipient partner is not a relevant partner, see CH23700.

Or exceptionally

  • if the recipient partner is a relevant partner, see CH23720,

the following rules apply

  • Your notice must name the other partner.
  • You do not need to give a copy of your notice to the named partner.
  • You do not need approval from the named partner.
  • The recipient partner’s appeal rights against the notice are as set out in CH23520.
  • If you seek the tribunal’s approval you do not need to give a summary of your reasons to each partner, although you may if you consider it appropriate. You should consider carefully and respond positively to any request by a partner for a summary of reasons, provided that doing so will not jeopardise your check.

Guidance about relevant partners is at CH21600.