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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Information Notices: Third party notices: Notice to an involved third party

Notices could only be issued to ‘involved third parties’ in the period 1 April 2010 to 31 March 2012. The data-gathering powers are used for information notices issued on or after 1 April 2012, see CH28000.

Some of the rules for a third party notice in CH23620 are different where the notice

  • is issued to an involved third party, and
  • is for the purpose of checking the tax position of a person, and
  • is regarding a relevant tax, and
  • refers only to relevant information or relevant documents.

For the definitions of ‘involved third party’ and ‘relevant information and relevant documents’ see CH25360.

The differences for notices to involved third parties are

  • You do not need the approval of the person or the tribunal.
  • You do not need to give a copy of the notice to the person whose tax position is being checked.
  • The involved third party can appeal against the notice on any grounds, except the requirement to produce its statutory records.

If you decide to seek tribunal approval for this type of notice, you must follow the guidance at CH24160. There is no right of appeal against a tribunal approved notice.