Tribunals

Third party notice

If you have not asked for, or have been unable to get the agreement of the named person the notice must be approved by the Tribunal.

The notice must name the person whose tax position you are checking.

You must make sure that:

• the person receiving the notice has been told the information or documents are required and have been given a reasonable opportunity to make representations
• any such representations have been summarised to the Tribunal
• the named person has been told why the information or documents are required from the third party.

However the Tribunal may approve a notice where the person has not been asked for the information or documents required or asked for their representations if it can be shown that these actions may prejudice the assessment or collection of tax.