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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Information Powers: TMA70/S20: Opportunity for the Taxpayer to Provide Information


The legislation states that the taxpayer must be given a reasonable opportunity to deliver the documents in question or furnish the particulars in question.

An informal request for the documents or particulars should be made to the taxpayer, even if this matter has been referred to at interview or in previous correspondence. You should write to the taxpayer

  • drawing attention to the powers available under Section 20(1)
  • setting out clearly what documents or particulars are required
  • indicating that a formal notice will be sought if the documents or particulars are not produced by a specific date. The time to be allowed should not be less than 30 days but more time may be given if, for example, extensive particulars need to be compiled
  • asking whether the taxpayer wishes to make any written representations which can be put to the Commissioners EM10112, and
  • including a short warning along the lines of ‘it can be a criminal offence intentionally to falsify, conceal, destroy or otherwise dispose of any of these documents before they have been produced to the Revenue’ EM10135.