There are various restrictions on what information and documents can be required by a taxpayer notice. It cannot require the taxpayer to provide for inspection:-

  • documents that are not in the taxpayer’s possession or power
  • documents relating to a pending appeal
  • journalistic material
  • personal records or information from personal records (as defined in S. 13 of the Police and Criminal Evidence Act 1984)
  • documents more than six years old at the date of the notice, unless approved by an Authorised Officer
  • privileged information or the privileged part of a document.


Normally a statutory auditor cannot be required to produce their audit papers or a tax adviser their advice papers.

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