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HMRC internal manual

Enquiry Manual

Information Powers: TMA70/S20: Time Limits for Third Party Notices




A notice under Section 20(3) does not oblige the person to deliver or make available any document the whole of which originates more than six years before the date of the notice. For example, if the first entry in a cash book is twenty years old and the last entry five years old, the book would not be barred. If all the entries were seven years old it would be out of date for a notice.

In cases of fraud the six year time limit will not apply if the Commissioner who consents to the issue of the notice approves. The Commissioner must be satisfied by the officer that there is reasonable ground for believing that tax has or may have been lost owing to the fraud of the taxpayer. The exclusion of the time limit must be expressed in the notice itself. Such cases will be particularly sensitive because they will involve disclosure to a third party that the officer thinks the taxpayer has been guilty of fraud. Before consent is sought from a Commissioner for such a notice, a report with the file should be made to contact link.

A notice cannot be given under Section 20(3) which relates to a taxpayer who has died more than six years before.