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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Information Powers: TMA70/S20: Head Office Powers



The power to enter premises will be authorised and used only by Head Office. If the tax fraud is serious enough to justify obtaining a search warrant, the case will normally be working at Criminal Investigations. Where, exceptionally, it is considered that the circumstances in a case working locally would justify the use of Section 20C powers, consult Criminal Investigations.

Taxpayer’s Identity Unknown

HMRC may be aware of the existence of serious tax irregularities but not of the identity of the person(s) involved. A tax adviser may, for example, have sold an avoidance scheme to a number of clients which is proved ineffectual in the case of one of them.

This power enables HMRC to serve a notice requiring the adviser to provide information about the others. Such notices may be of use if it is known that arrangements have been made to hide or launder monies from tax evasion through financial institutions, nominees or others.

This power may be used only with the consent of a Special Commissioner, who must be satisfied that there are reasonable grounds for believing that there has been serious tax default by the person(s) concerned and that the information requested is not readily available from another source. Its use will therefore be limited to the most serious instances of avoidance and evasion.

You should send a brief report to contact link in any apparently worthwhile case.