Paragraph 27 Schedule 18 Finance Act 1998 is the information
power that supports CTSA enquiries. Paragraph 27 allows HMRC to
require a company to which a notice of enquiry has been given to
produce documents and provide information that is reasonably
required for the purposes of the enquiry.
A notice under Paragraph 27 can only be given to the company
whose return is under enquiry. In other words this Paragraph only
enables requests for first party information. This provision cannot
be used to obtain information from
However, if you require information from directors, the
information power to use will depend on whether the information can
be required as part of an enquiry into the director’s own
returns (Section 19A TMA). If an enquiry into the director’s
return cannot be opened, because the time limits for opening an
enquiry have expired, or an enquiry has already been completed, and
you need to request documents from the director in order to check
the company’s return, you can do so under Section 20(3) TMA.
The Val 222 should be used to request the Inspector to issue
a notice for information you need from a taxpayer company. If you
wish a notice under Paragraph 27 Schedule 18 Finance Act 1998 to be
issued, you should obtain the consent of your Team Leader.
| Additional Guidance: SVM150000 |
