Multinational Top-up Tax and Domestic Top-up Tax

MTT55160 - Administration: Compliance: Compliance checks: Information notices

Most people will co-operate fully when asked for information or documents. However, to address cases where they do not, Schedule 36 FA 2008 has been extended in its application to cover MTT. The basic rules and guidance as set out in the law and guidance at CH20000  will therefore apply for MTT.

There are safeguards to ensure that HMRC acts reasonably and that any action HMRC takes is appropriate to the circumstances and does not unreasonably interfere with a person’s rights under Article 8 of the Human Rights Act. See CH21340.

The information or documents HMRC ask for or the inspection HMRC carries out must be reasonably required to check a person’s tax position (see CH21520). HMRC cannot require a person to give us or require them to allow us to inspect some types of information (see CH22000). Amongst other things, this will include documents that were created for the dominant purpose of a tax appeal (see CH22160).

There are Factsheets covering the use of our information and inspection powers and these should be issued as appropriate. See CH21200.

An overview of HMRC powers to ask for information or documents is at CH20200. Detailed guidance starts at CH23000.

An overview of HMRC powers to carry out an inspection is at CH20250 and detailed guidance starts at CH25000.

This is set out in paragraph 68, schedule 14 to Finance (No.2) Act 2023.

Filing member as primary point of correspondence

Requests for information and information notices should be given to the filing member, at least in the first instance. See MTT51000+.