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HMRC internal manual

Specialist Investigations Operational Guidance

HM Revenue & Customs
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Information and inspection powers: Schedule 36 FA 2008: records to be kept

A copy of all formal notices issued under Schedule 36 FA 2008 should be kept by the Team Leader in an establishment file. A record should also be kept in that file of cases where:

  • the person to whom the notice was sent was not given an opportunity letter (paragraph 3(2)(c))
  • reasons for the notice were not given to the taxpayer (paragraph 3(2)(e))
  • a copy of a third party notice is not provided to the taxpayer (paragraph 4).