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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
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Information & Inspection Powers: Information Notices: Identity unknown notice: Groups of undertakings

An identity unknown notice may be issued to a parent undertaking for the purpose of checking the tax position of one or more subsidiary undertakings whose identities are not known.

Who can issue the notice?

Only an authorised officer can issue an identity unknown notice, see CH262500.

Approval

The approval of the tribunal is not needed for such a notice. However, the authorised officer may seek tribunal approval. You would be most likely to want the authorised officer to seek tribunal approval where you need to protect your information from premature exposure at an appeal hearing against the notice, or where there are grounds to invoke the possibility of criminal sanctions for destroying documents, see CH27200.

Appeals

The parent undertaking may appeal against a notice or any requirement of a notice on any grounds except

  • where the requirement is for information or documents that form part of the statutory records of the parent or any of its subsidiaries
  • where tribunal approval for issue of the notice has been obtained.

FA08/SCH36/PARA35(5)