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HMRC internal manual

Compliance Handbook

Information & Inspection Powers: Inspection Powers: Documents you cannot inspect

When you intend to look at documents during an inspection, the limited range of documents the law allows you to inspect (see CH25100 and CH25280) is further limited where any of the restrictions in CH22000+ apply.

If a document is present at an inspection then clearly it is within the person’s power or possession. However, even if it is, you cannot inspect the document if it falls within the other restrictions listed at CH22100.

If you are offered documents to inspect that are on the list at CH22100, always remind the person that you have no power to inspect them. If they are still offered you may inspect them but make a full record of the circumstances in which the documents were offered for review.