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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: third party notice: partnerships: notice to a partner whose tax position is being checked, to check more than one other partner

When you give a notice to a partner, whose tax position is being checked, to check the tax position of more than one other partner in their capacity as partners, see CH23720.

  • The notice you issue is a combined taxpayer (for the recipient partner) and third party notice (for the other partners). SEES Forms and Letters contains a combined notice - IIP22.
  • Your notice only needs to say that it is for checking the tax position of more than one partner and name the partnership. This enables you to avoid having to make unnecessary (and possibly incomplete) lists of partners. But where listing the partners is likely to help the recipient to comply with the notice, you should do so. You should also name the affected partners in your description of documents and information where this helps to identify what you are seeking.
  • You do not need to give a copy of your notice to the other partners.
  • You do not need approval from the other partners.
  • You must ensure that the conditions for a taxpayer notice see, CH23520, are met in relation to the recipient of your notice.
  • The recipient partner has taxpayer appeal rights against the notice as it relates to their tax position and the tax position of the other partners.
  • If you seek the tribunal’s approval you do not need to give a summary of your reasons to any 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.