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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Information notices: Taxpayer notice: specific rules: Appeals

A ‘taxpayer notice’ is a written notice to a person requiring them to provide information or produce documents reasonably required to check their tax position. For the use of first and third party information powers to check the tax position of one or more partners at the same time, see CH225600.

The person can appeal against

  • the notice or
  • any requirement in the notice, see CH24320.

However, there is no right of appeal against

  • a requirement to provide information or produce any document that is part of the person’s statutory records, see CH21700
  • a notice or any requirement that requires only statutory records of any person relating to

    • the supply of goods or services, or
    • the acquisition or importation of goods from an EU member state, or
    • the importation of goods from outside the member states in the course of carrying on a business, or
  • a notice or any requirement approved by the tribunal. This is because the independent approval safeguards the person’s rights.

See also the general restrictions and rules for information notices at CH22100 and CH23220, and the specific rules for taxpayer notices in this section at CH23522 to CH23536. The operational guidance about taxpayer notices starts at CH223000.