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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Information Notices: Identity unknown notice: Notice to an involved third party

Notices could only be used to ‘involved third parties’ in the period from 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 an identity unknown notice in CH23900 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 or class of persons, 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 an identity unknown notice to an involved third party are:

  • You do not need the approval of the tribunal.
  • The involved third party can appeal against the notice on any grounds, except the requirement to produce its statutory records, see CH21700.