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HMRC internal manual

Specialist Investigations Operational Guidance

Information and inspection powers: Schedule 36 FA 2008: non-compliance with a third party notice

Where a third party notice has not been complied with and proceedings should be taken, a report should be made to the Technical Manager (Powers and Penalties). It will not normally be necessary to send the whole file, but you should send copies of the following documents:

  • the brief for the approval hearing
  • your note of what happened at the approval hearing
  • the opportunity letter
  • the formal notice
  • any correspondence exchanged about either the opportunity letter or the notice
  • a brief note of any other relevant matters, including confirmation that the documents are still necessary to your enquiry.