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HMRC internal manual

Compliance Handbook

How to do a compliance check: applying to tribunal for approval to give a Sch36 FA08 notice and preparing for the hearing: overview

This guidance describes the steps that should be followed once you have decided to make an application for approval of an information or inspection notice under Schedule 36 FA08 and assumes that you have read the guidance up to the point of seeking tribunal approval. For example, for a taxpayer notice you have read the guidance from CH223100 to CH223400.

  • Step 1 explains what to consider before making an application to the tribunal, see CH265020.
  • Step 2 explains the need to obtain the agreement of an authorised officer, see CH265040.
  • Step 3 explains how to prepare the application on form IIP20, see CH265060.
  • Step 4 explains about without notice and in private application, see CH265080.
  • Step 5 explains how to put together a brief to accompany the application, see CH265110.
  • Step 6 explains how to make the application, see CH265130.

There is further guidance about how to prepare a bundle of documents for the hearing and how many copies of which documents to take at CH265140.

CH265170 explains what happens at the hearing and how to conduct yourself.


It is advisable for individuals who are inexperienced in presenting cases at tribunals to undertake the presentation skills training. The courses in the Learning Prospectus which prospective presenters may find useful are:

  • Presentation Skills
  • Powers, deterrents and safeguards guidance
  • Sch36 FA08 Compliance Checks High Level Awareness