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HMRC internal manual

Specialist Investigations Operational Guidance

Information and inspection powers: Schedule 36 FA 2008: opportunity letters

In order to ensure that an ‘opportunity letter’ issued under paragraph 3(3)(c) covers all of the ground, it is best practice to draft the description of information and document it as if it were for the formal notice. The subsequent notice may be altered for clarity or drafted more narrowly to reflect representations received, but it must not be drafted more widely.