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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
Updated
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Information & Inspection Powers: Information Notices: Third Party Notice: Partnerships: Notice given to person other than a partner

Special rules apply to partnerships and third party notices. These are in addition to, or in some instances they disapply, the general restrictions, see CH22100, and general rules, see CH23220.

The special rules apply where a notice is given for the purpose of checking the partnership tax position of one or more partners. They differ depending on whether the notice is given to

  • a person other than a partner, see below, or
  • a partner, see CH23700.

Notice given to a person other than a partner

Where you give a third party notice to any person who is not one of the partners, for the purpose of checking the tax position of two or more partners (in their capacity as partners)

  • the notice only needs to say this and name the partnership. It does not need to show the names of the individual partners concerned
  • you only need the approval of one of the partners concerned to issue a taxpayer approved notice
  • you only need to send a copy of the notice to one of the partners concerned, and
  • you only need to send a summary of your reasons to one of the partners concerned if you apply for tribunal approval to issue the notice, see CH24160.

The recipient’s appeal rights against this notice are detailed in CH23620.