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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Information Powers: TMA70/S19A, TMA70/SCH1A/PARA 6 and FA98/SCH18/PARA 27: Accountants ‘Link Papers’

A notice under Section 19A or Para 27 can only be given to the taxpayer. In other words, it only enables you to obtain first party information.

Link papers are normally available to the taxpayer (the first party) but are held by their accountant (a third party). See EM10152 for an explanation of linking documents.

If an informal approach for linking information is unsuccessful, you will be able to use Section 19A or Para 27 to require

  • sight of the papers if they are in the power or possession of the taxpayer EM10202 or
  • the production of particulars by the taxpayer EM10204 

to explain how entries in the return are linked to the business or other records.

However if the taxpayer is unable to produce the particulars you will be able to use TMA70/S20(3) to obtain from the accountant documents containing the relevant information EM10150+.