SVM118030 - Statutory Notices: Section 19A Notices



Four points about the S.19A procedure should be noted:-


  • the process can only be used in SA cases where there is an open enquiry;
  • you can only use it to obtain information/documents. Information means factual material which you require to make a valuation. It does not include the taxpayer’s opinion of value, arguments supporting that opinion or an acceptance or rejection of a valuation proposal you have made previously. So as to avoid difficulties in this area (and whilst you should put forward your opinion of value as soon as you can), you should not generally put forward a value to taxpayers/agents at the same time as you are seeking from them information which you need in order to come to a firm opinion on that value.
  • Section 19A is designed to obtain first party information i.e. information held by or which was available to the taxpayer. There are powers (see SVM118010 above) for obtaining third party information.
  • You should confirm the Inspector is content for the Section 19A procedure to be used.

Additional Guidance: SVM150000