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HMRC internal manual

Compliance Handbook

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

A tax agent does not have a right of appeal against a file access notice given to them.

A third party has a right of appeal against a file access notice given to them, but only on the grounds that it would be unduly onerous to comply with it, see CH183000.

Appeals and requests for reviews are handled as if they were appeals against direct tax decisions. Detailed guidance about reviews and appeals is at ARTG2100.

If you have referred your case to the Commissioners’ Advisory Accountant (CAA) you must tell the CAA team about the appeal, see CH881600.

If money laundering issues arise, or you have already reported an agent to Anti-Money Laundering Supervision (AMLS), see CH881150.