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HMRC internal manual

Compliance Handbook

Agent operational guidance: dishonest tax agents: getting access to an agent’s files: file access notice: who we can give a notice to

You can give a file access notice to a tax agent who has been

  • given a conduct notice and any appeal has been confirmed in your favour, or the time limit to appeal has expired
  • convicted of an offence of fraud or dishonesty in relation to tax

and, in relation to those tax agents,

  • any other person (a third party) that you believe holds documents.

The person you give the notice to is the ‘document-holder’.

The notice requires the person to provide ‘relevant documents’, see CH182600.