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HMRC internal manual

Enquiry Manual

Information Powers: TMA70/S20: Outline



TMA70/Section 20 is available to officers as well as action under Regulation 10 (‘precepts’) for all years and Section 19A for ITSA years and Paragraph 27 Schedule 18 FA1998 for CTSA years.

The dedicated SA powers must be used where possible for SA years. If you believe that there are exceptional reasons why Section 20(1) should be used even though an SA enquiry is open or could be opened, you must make a report to contact link before proceeding EM10001.

Section 20 powers are not to be used in trivial or unsuitable cases but equally you should not hesitate to use them to overcome delay or objections to your reasonable requirements where you have good reason for taking this course of action.

The use of Section 20 powers is restricted to officers who have been authorised for this purpose by HMRC Commissioners EM10107. Notices, which can be issued to taxpayers or third parties require the consent of an Appeal Commissioner. Section 20 notices are not linked to specific appeals or assessments but can be sought where the authorised officer reasonably thinks their use relevant to a tax liability.

The guidance is broadly structured:

  • Section 20(1) Information from the taxpayer EM10105+
  • Section 20(3) Information from third parties EM10117+
  • Section 20(3) Information from Banks EM10126+
  • Section 20(3) Accountants Working Papers EM10150+
  • Section 20B(3) Barristers, Advocates or Solicitors EM10160+
  • Miscellaneous EM10200+