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HMRC internal manual

Enquiry Manual

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HM Revenue & Customs
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Information Powers: TMA70/S19A, TMA70/SCH1A/PARA 6 and FA98/SCH18/PARA 27: Notices - Example 1

Example 1

You want an analysis of the entry of £150,000 in the ‘legal and professional costs’ box of the Standard Accounts Information (for example, to determine whether the entry contains any disallowable element).

A Section 9A opening letter includes an informal request for

  1. a description of all single items of legal and professional costs over £5,000
  2. the solicitors’ and accountants’ bills relating to items included in a. above.

If the information is not provided the Inspector can issue a Section 19A notice for

  • the particulars at a.
  • the documents at b.

As the solicitors’ bills may contain information concerning legal advice, the informal request and notice should each contain a paragraph concerning legal professional privilege EM10165.