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HMRC internal manual

Specialist Investigations Operational Guidance

Investigation work: interviews with third parties: notes of meeting with third party not to be issued

It will not generally be appropriate to issue notes of a meeting with a third party. The first party is not entitled to see these notes in civil cases other than following a request under the Data Protection Act.

The meeting does not concern the third party’s own tax affairs, therefore it is not appropriate that notes should be issued to the third party.

If the meeting changes its nature and the third party becomes a first party then a note of the meeting should agreed with the taxpayer on the basis which is appropriate for the Code under which the case is to be worked.