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HMRC internal manual

Compliance Handbook

HM Revenue & Customs
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Agent operational guidance: dishonest tax agents: getting access to an agent’s files: file access notice: the notice

You must specify in the notice where documents are to be provided and to whom. In doing so you must take a reasonable approach. If you do not, it is possible that the tribunal will not approve your application to issue a notice.

Typically you will want the documents delivered to you at your office. You will normally have discussed this with the document-holder before issuing the notice, see CH882300. They may also have made representations to you when you gave them an opportunity letter, see CH882530.

You should accept a place chosen by the recipient if it is reasonable and practical; this might be collection from their own or another’s premises or it might be delivery to another HMRC office.

If the person suggests production of a document at an unsocial hour of the day or in an unreasonable location you must explain why the time or place suggested by the recipient of the notice is not reasonable and specify an alternative.