Where and When Documents should be Produced

Para. 7 (1) says that where a person is required by an information notice to provide information or produce a document, the person must do so at such time, by such means and in such form (if any) as is reasonable.

The officer doesn’t have to specify where and when the information or documents have to be produced and will usually be prepared to agree a convenient time and place with the taxpayer. It was established in Johnson v Blackpool Commissioners and CIR (1996) BTC 237, that it is not reasonable for the person to suggest production of a document at an unsocial hour of the day or in an unreasonable location.

If a reasonable place and time cannot be agreed, the officer can specify them either when issuing the notice or after it has been issued. They cannot, however, specify a place that is used solely as a dwelling.

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