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HMRC internal manual

Compliance Handbook

How to do a compliance check: information powers: rules that apply to all notices: accountants’ working papers: specimen letter for linking documents

Dear Sir or Madam

John Smith

Request for documents (Paragraph 2 Schedule 36 Finance Act 2008)

I am considering an application to the First-tier Tribunal for consent to the issue of a notice to you under Paragraph 2, Schedule 36 of the Finance Act 2008 in respect Mr Smith.

Paragraph 3(3)(c) Schedule 36 provides that before any notice is issued you must have been given a reasonable opportunity to deliver or make available the documents which may be specified in the notice.

Will you please deliver or make available to me by…………….. [allow at least 30 days from the date of the letter] all documents in your possession or power which contain information explaining [see the examples in CH231600].

Paragraph 42(1) Schedule 36 makes it a criminal offence to intentionally falsify, cancel, destroy or otherwise dispose of any document which has been requested to be produced by a third party notice or which has been specified in the informal request above.

Yours faithfully

If you are proposing to send an excise information notice, see the specimen opportunity letter at CHApp2.9 (Word 30KB).