Unless a third party notice is given to a partner or a parent company or relates to certain parts of Statutory Records, HMRC must always obtain either:-
No approval or agreement is required for a third party notice issued to:-
Para. 34 provides that no appeal is needed for a third party notice that refers only to information or documents that form any part of a person’s statutory records and relate to:-
Neither the taxpayer nor the third party has the right to be present at or make representations to the hearing of an application for approval for issuing a third party notice. However if they make representations to the officers, these must be fairly summarised and placed before the Tribunal. If the representations are made in writing, the written document must be given to the Tribunal.
There is no appeal against a third party notice which has been approved by the Tribunal (FA 2008, Sch. 36, para. 29 (3)).