The conditions that have to be met before the Tribunal can give its approval for a third party notice are set out in FA 2008, Sch. 36, para. 3 and 4 and are as follows:-

  • The application is made by or with the agreement of an authorised officer
  • The Tribunal is satisfied that, in the circumstances, the officer is justified in issuing the notice
  • The person to whom the notice is addressed has been told that the information or documents referred to in the notice are required and given a reasonable opportunity to make representations to the officer (unless this condition is disapplied by the Tribunal)
  • The Tribunal has been given a summary of any representations made by the person (unless this condition is disapplied by the Tribunal)
  • The person whose tax position you are checking has been given a summary of the reasons why the information or documents from the third party are required (unless this condition is disapplied by the Tribunal
  • The notice names the person whose tax position is being checked.

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