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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Information Notices: Taxpayer Notice: Specific rules: Partnerships

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.

Where a Self Assessment return is a partnership return, or where a partnership has made a claim or election, the conditions on page CH23526 apply as if the return, claim or election had been made by each of the relevant partners, see CH21600, for that chargeable period. CH21600 also gives information about a partner’s rights to access partnership books and records.

The partners are only regarded as having made an SA return in their capacity as partners. So if a person is regarded as having made a partnership return for a period but has not yet made their personal SA return you do not need to give notice of enquiry into the partnership return if you are checking the person’s income tax position in respect of anything other than their share of partnership profit.

Similarly, where a stamp duty land tax return or annual tax on enveloped dwellings return, or claim is made by or on behalf of the members of a partnership, each partner is regarded as having made the return or claim.

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.