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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Information Powers: TMA70/S20: Copy of Notice and Written Summary to Taxpayer




You must send the taxpayer a copy of the section 20(3) notice and a summary of reasons for applying for consent to the notice EM10113. The summary and copy should be sent with a suitable covering letter at the same time that the third party notice is issued.

These requirements can be lifted under Section 20B(1B) with the prior direction of a Commissioner. This would normally be sought at the same time as consent for the notice. The Commissioner must be satisfied that you have reasonable grounds for suspecting the taxpayer of fraud. Where you consider that the provision should be used you should submit the file with a covering report to contact link.

If the Section 20B(1A) requirement is lifted by virtue of Section 20B(1B), then a written summary of the reasons for the Section 20(3) application, required by Section 20(8E), is not to be sent.