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HMRC internal manual

Specialist Investigations Operational Guidance

HM Revenue & Customs
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Information and inspection powers: authorisations and approvals: exceptional and difficult cases

In the following cases, a report should be made to the Technical Manager (Powers and Penalties), whose agreement is necessary before an information notice is issued. (This agreement is in addition to any authorised officer agreement which may be necessary).

  • Where the recipient of the notice is a minor or is incapacitated. (Note that it may be better to issue a notice to the guardian of a minor, if it is the guardian who is in fact likely to have the information).
  • Where the recipient of the notice, or the taxpayer, is a relevant lawyer: see SIOG7610.

The Technical Manager (Powers and Penalties) should also be consulted in other cases where there are exceptional circumstances likely to affect the use of information powers.