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.