Although most taxpayer notices will be issued without the approval of the Tribunal, HMRC will seek their approval where:-

  • the tax at risk is large, the time-limits for making an assessment are closed and an appeal may mean that the tax cannot be quantified and assessed
  • the taxpayer has a history of making appeals to delay matters and then withdraws them at the last minute
  • there is a history of refusing to provide information
  • the officer wishes to protect their information from being disclosed at an appeal hearing on the notice – for example where they hold information from an informer or a third party
  • they have reason to believe that documents may be destroyed and it is necessary to consider criminal proceedings.


There is no appeal against a taxpayer notice that has been approved by the Tribunal.

If HMRC want to inspect documents and business premises at the same time, they can ask the Tribunal for their approval for both the inspection visit and the taxpayer notice.

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