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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Information Notices: Appeals: Appealing against an identity unknown notice

A person who has received an identity unknown notice may appeal to the tribunal against

  • the notice, or
  • any requirement in the notice

except that there is no right of appeal against

  • a requirement in a notice given to a parent undertaking for the purpose of checking the tax position of one or more subsidiary undertakings, to produce any document that forms part of the statutory records, see CH21700, of the parent undertaking or any of its subsidiary undertakings, see CH23740, or
  • a requirement in a notice, given to a partner for the purpose of checking the tax position of one or more other partners in their capacity as such, see CH23700 and CH23720, to produce any document that forms part of that partner’s statutory records, see CH21700.

The only ground of appeal to the tribunal against an identity unknown notice is that it would be unduly onerous, see CH24420, to comply either with the notice or the requirement. Any other challenge to an identity unknown notice would be through an application for judicial review.

See the Appeals, Review & Tribunals Guidance (ARTG) for full guidance on the appeal and review procedure.

FA08/SCH36/PARA31