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HMRC internal manual

Enquiry Manual

Information Powers: Tax Cases: R v CIR ex parte Archon Shipping Corporation and Others, 71 TC 203

The Judgment emphasises the responsibilities of both the authorised officer, as decision maker, and the Commissioner (now the Tribunal) as monitor of the decision.

The safeguard for the taxpayer is the need to satisfy a Commissioner (now the tribunal) that the serving of the notice is justified. The officer has a heavy responsibility in the application for consent to disclose to the Commissioner (now the tribunal) everything that is or may be relevant to the decision on the notice.