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HMRC internal manual

Compliance Handbook

Data gathering: Penalties: Material document

A material document

A document is a ‘material document’ if, at the time when the data-holder acts, see CH29520, the data-holder has

  1. received a data-holder notice requiring them to provide the document or data contained in the document, or
  2. not received such a notice but we have told them that we will, or are likely to, issue a notice.

Not a material document

A document is not a ‘material document’ under (a) above if the data-holder has already compiled with the data-holder notice, unless

  • we have notified the data-holder in writing that they must continue to preserve the document, and
  • that notification has not been withdrawn.

A document is not a ‘material document’ under (b) above if more than 6-months have lapsed since the data-holder was (or was last) informed that we would, or likely to, issue the notice.