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HMRC internal manual

Specialist Investigations Operational Guidance

Information and inspection powers: Schedule 36 - approval hearings: record of hearing

Because neither the intended recipient nor the taxpayer has the right to attend an approval hearing, it is essential that you make a full record of the hearing. This will help to safeguard the Department’s position in the event of subsequent action such as an application for judicial review. In particular you must make a note of any questions put by the tribunal.